Aledade has developed a guide to help the practices that participate in its ACOs successfully implement telehealth, which is a critical resource during the COVID-19 pandemic. This guide provides high-level information and recommendations to get you started with telehealth. Learn more and download the guide here.
Travis Broome, Vice President of Policy at Aledade, discusses CMS allowing widespread use of telehealth by medical providers and how it has the potential to improve the way health care is delivered for years to come.
The Federal government has removed many barriers to the implementation of telehealth and we discuss those changes here. Please remember that state laws and regulations dictate who can perform telehealth encounters and the patient consent process and also impose some additional requirements for conducting telehealth encounters Just because Medicare or another payer will pay for a telehealth service does not mean that their billing requirements ensure compliance with state laws and regulations. State-specific guidance is forthcoming in the full Telehealth toolkit that will be issued later this week.
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On March 17, 2020, CMS issued guidance on the telehealth waiver. Retroactive to March 6, 2020, qualified professionals (MD/DO/NP/PA/CNS) can bill telehealth anywhere in the country and no matter where the patient is, including if they are home. A full list of telehealth services is available here. This allows practices to replace office visits with video-enabled visits when the patient is at home, in the parking lot, or anywhere. This requires the use of “audio and video capabilities that are used for two-way, real-time interactive communication.” Physicians cannot replace an office visit with just a phone call. CMS already covers “virtual check-ins” over the phone (G2012)and of course chronic care management services, which does not require a face-to-face visit. If you are providing telehealth out of state, please be aware that many states have restrictions that may not allow out of state telehealth.
We have received many inquiries as to whether or not the telemedicine legislation will also enable Rural Health Centers and Federally Qualified Health Centers to bill for services. This waiver applies to all qualified professionals regardless of where they work, so RHCs and FQHCs can utilize this new authority. CMS has issued frequently asked questions. Our most frequent are also below:
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Medicare will pay the distant site practitioner (i.e. the one doing the CPT-described service) the facility rate for the service. Facility rates can be found in the physician fee schedule look up tool. Physician offices should use place of service 02. While we continue to wait for definitive clarification from CMS on the telehealth waivers for FQHCs and RHCs, we believe the surest path is to bill Part B using just your Medicare enrolled TIN for telehealth services under the waiver until CMS clarifies their guidance. Will update as soon as CMS clarifies. HRSA is clear that telehealth is in-scope for both new and established patients. If a FQHC and RHCs do bill Part A using their CCN, they should use the GT modifier.
We reviewed the list of CPT codes both eligible for the telehealth and likely to be used by our practices. Only AWVs require an element of patient interaction unlikely to be available when the patient is not at a health care facility. We encourage you to use E&M codes in lieu of AWV codes if appropriate. Our review of codes can be found here. You can not bill any code that you do not meet the requirements for. In those cases, either downgrade the code or consider billing an online check in (99421-99423).
Yes, the HHS Office of Civil Rights (OCR) issued a notice that specifically allows for use of private consumer technologies. However, purpose-built telehealth tools have many features such as billing assistance, consent management, waiting rooms, etc. that are not available in consumer technologies. If you use consumer technology, you need to ensure all state-required mandates are met, including requirements for patient consent The only thing the waiver does is waive enforcement of the privacy and security requirements of the technology itself.
The federal legislation required physicians to have an established relationship with a patient in order to use these new flexibilities, but CMS has said “HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency.” This means that the “established relationship” federal requirement essentially does not apply in the current environment.
Practices can charge a co-pay, however HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.