TELEHEALTH PLANNING

Planning for maintaining telehealth and in person services is a bit difficult since there is not a Centers for Medicare and Medicaid Services (CMS) timeline and we don't know what this will look like post COVID. We do know telehealth services will not be the same in our post world. Looking at expanding visits for out of hospital patients is an option, TCM has been approved as a CMS telehealth services. We recommend establishing a workgroup to focus on the technology challenges, varying reimbursement guidance and back-end denials, etc. ?

Based on continued areas of question or concern the following illustrates what we know now about these areas in telehealth.Visit the CMS Current Emergencies website for up-to-date information. Sign up for CMS’ weekly teleconferences that address frequently asked questions.

 

 

CMS EXPANDED FLEXIBILITY – APRIL 30, 2020

CMS issued additional flexibilities for providers and payors. On April 30, CMS revised the blanket waivers and issued a new interim final rule with a comment period. Review MedAxiom's rule summary here. The expansion of practitioners that may furnish services via telehealth continues to provide safety for patients and care teams while offering many needed services for physical, speech and occupational therapies. CMS will provide comparable reimbursement for some telephone only services. This will assist us with patients who do not have access to video services and ramp up our necessary visit volumes. Additionally, programs with provider-based billing or HOPD clinics will be able to bill for the facility portion of there services as the originating site during the PHE.

 

 

DETAILS OF REIMBURSEMENT

Telephone codes (99441–99443) are now defined as telehealth services. CMS reimbursement rates for these services were increased to match the reimbursement for 99212-99214 effective March 1, 2020, through the end of the PHE, which is undetermined. This table below outlines updated national facility and non-facility fees and wRVUs. It is important to verify with your state Medicare Carrier (MAC) guidance regarding re-processing claims and payment.​

  • Retroactive payment increases to CPT codes 99441 to 99443 for telephone E&M services
  • Added to CMS telehealth approved list – audio only (telephone) – usual POS and modifier 95

 

 

TELEPHONE VISIT GUIDANCE

The audio only (telephone) visit codes have parameters that are imperative to operationalizing. Below are the top considerations for coding and billing these services as outlined in AMA CPT® Guidelines.

 

 

DOCUMENTATION TIPS

In addition to coding guidelines for the audio services, documentation remains a key part to supporting the medical necessity of these services during the PHE. For telephone codes 99441-99443, below are some documentation tips to share with providers.

 

 

CMS EXPANDED LIST – APRIL 30, 2020

The CMS list of approved telehealth services was also updated to include a status and audio only requirement. The expanded list is available in MedAxiom's Virtual Services Coding Tool.

 

 

INTERIM FINAL RULE SECTION

In the March 2020 rule, CMS released different times for selecting CPT codes for 99201–99215 which caused some confusion. The second interim-final rule released on April 30, 2020, provided clarification to use CPT EM code times. On an interim basis, CMS is allowing these rules to be applied to office/outpatient visits performed via telehealth during the time of the PHE.

 

 

 

HOSPITAL BASED PRACTICES (PBB/HOPD)

Telehealth Facility Fee
  • A registered outpatient of the hospital is receiving a telehealth service, the hospital may bill the originating site facility fee to support telehealth services furnished by a physician or practitioner who ordinarily practices there​
  • Includes when the patient is at home and the home is serving as a temporary provider-based department of the hospital
  • Q3014 describes the Medicare telehealth originating sites facility fee​
  • Documentation requirement necessary for facility as well as professional service provided 
  • No reference or information regarding – G0463 (Facility EM)
 

 

RURAL HEALTH CLINICS (RHC)

  • CMS is paying for telehealth services during the PHE​
  • Previously, these clinics could not be paid to provide telehealth expertise as "distant sites"
    • Telehealth distant sites furnished between January 27, 2020, and June 30, 2020, must report G2025 with the CG Modifier
    • Modifier "95" may be appended but is not required
    • Claims will be paid at the RHC’s All Inclusive Rate and automatically reprocessed on July 1, 2020, at $92.03
    • Beginning July 1, 2020, RHC’s should no longer use the CG modifier with HCPCS code G2025
  • See guidance for FQHCs as it differs a bit
 

 

KEY POINTS “OTHER” CODE PHE FLEXIBILITIES

For other virtual services including RPM, there have been limited changes to flexibilities. The only change is for reporting RPM services for suspected or confirmed diagnosis of COVID-19. These RPM services during the PHE do not require a 16-day period of monitoring in order to bill.

 

 

REMOTE PATIENT MONITORING

Over the last few years, CMS has reimbursed for many virtual services. With COVID-19 these services have come to the forefront. The U.S. Food and Drug Administration has provided expanded guidance for remote patient monitoring (RPM). The intent of RPM devices is to digitally connect and support monitoring of symptom progression, etc. AMA CPT and CMS have provided guidance on the billing and coding for these services.

 
Areas of Guidance

 

 

 

 

RPM CLINICAL DOCUMENTATION

RPM does require clinical documentation to support the ordering, medical necessity and services provided. The following areas are recommended as a best practice to include in the documentation. Education for the clinical teams and providers is important.

 

 

CONSIDERING CCM OR PCM

CMS recognizes Chronic Care Management (CCM) as a critical component that contributes to better health and care of patients. Across all specialties claims data largely show that these services have been under utilized. This is an opportunity to offer improved care coordination and reimbursement for care team time providing proactive engagement with patients. Several studies have shown that the impact of revenue for providers is $75,000 plus annually and the savings in length of stay, readmissions, etc. Is evident. MedAxiom will continue to explore these initiatives and the opportunities for CV practices post COVID-19.

CCM and PCM have many regulatory and operational impacts. CMS offers guidance for patients and providers:

 
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