Telehealth Updates to Help With COVID-19 – What You Need to Know

The spread of the COVID-19 is requiring new ways to provide healthcare to minimize patients coming into the office and potentially spreading the disease to those who are not infected. As a result, The Department of Health and Human Services (HHS) and Centers for Medicare and Medicaid Services (CMS) have made some adjustments to the delivery and payment of telehealth services. We compiled an overview of key changes:

Revisions to Telehealth Reimbursement
Effective March 6, 2020, CMS expanded the telehealth benefit on a temporary and emergency basis under the 1135 waiver authority and Coronavirus Preparedness and Response Supplemental Appropriations Act. What this means to you as a physician (or other healthcare practitioner) is that Medicare will pay for office, hospital and other visits that are provided via telehealth services. Previously, seniors who lived in rural areas and were seen at certified sites were the only ones covered for this benefit. Unless indicated, the codes can apply to new patients as well as established patients under the 1135 waiver.

Telehealth Description
Telehealth and telehealth services refer to a virtual healthcare visit where a physician and patient exchange medical information via technology that includes both video and audio exchanged at the same time. This technology helps a patient to improve their health condition without having to go into a physical office and for the physician, these visits are paid the same as an in-person visit. Other healthcare practitioners who can provide telehealth services include nurse practitioners, clinical psychologists, and licensed clinical social workers.

Telehealth Codes and Therapy Notes
For billing purposes, there are three types of Medicare virtual care visits – telehealth, virtual and e-visits. Also note under the 1135 waiver that the HHS Office of the Inspector General (OIG) gives healthcare providers the flexibility to reduce or waive any patient copays or cost-sharing for telehealth visits paid by federal healthcare programs. The complete list of telehealth codes can be found here but we have broken down the highlights for you below.

Telehealth Visits
These visits involve using telecommunication technology (interactive audio and video telecommunications system) to replace an in-person visit with a patient. The telehealth visit is conducted in real-time.

The billing codes include:
99201-99215          Office or Other Outpatient Services
G0425-G0427        Telehealth consultations, emergency department
G0406-G0408        Follow up inpatient telehealth consultation, information furnished to beneficiaries in hospital

Virtual Check-Ins
Medicare patients from any location (not just rural) can have a brief communication with their physician by telephone or exchanging information through video or image. These virtual visits must be initiated by the patient, but providers may need to reach out to patients to let them know the service is available. As well, the provider must inform the patient they will be charged for the service and receive patient consent. The intention of these visits is to talk briefly to the doctor to avoid coming into the physical office if possible. These visits cannot be related to a medical visit conducted the previous 7 days or result in a visit in the next 24 hours. The patient must verbally give permission to receive the check-in service and Medicare coinsurance and deductible would generally apply.

The billing codes are:
         
HCPCS G2012     
This covers the physician’s response to a patient’s concern via telephone, audio/video, text messaging, email or through a patient portal, 5-10 minutes of medical discussion. This cannot be related to a previous E/M service       provided within 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment.

HCPCS G2010
This code applies to captured video or images that are sent to a physician (separate from these virtual check-in services). Includes remote evaluation, including interpretation with follow up with the patient within 24 hours. This cannot be related to a previous E/M service provided within 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment.

E-Visits (Online, Digital)
This is for a virtual visit with an established patient in any location (not just rural) and communications are performed (online digital evaluation and management service) in an online patient portal, via secure email, or other secure digital method. The patient must initiate the visit and communications can occur over a seven-day period. The following codes do not cover non-evaluative electronic communication of test results, appointment scheduling or other types of communication that does not include E/M.

CPT 99421               $15 for 5-10 minutes, cumulative time over 7 days
CPT 99422               $30 for 11-20 minutes, cumulative time over 7 days
CPT 99423               $50 for 21-plus minutes, cumulative time over 7 days
HCPCS G2061        as above, but with a qualified non-physician healthcare professional
HCPCS G2062        as above, but with…
HCPCS G2063        as above, but with…

Note Taking for Telehealth Services
It is important that when you document the telehealth visit, you indicate what type of telehealth service you provided. Other than that, you would document the service the same as a face-to-face office visit, which includes patient history, review of symptoms, consultative notes or other information that helped you to make a medical decision and patient consent. Also include the location of where you are, the patient’s location and the names of anyone else who participated in the telehealth service.

Revised HIPAA Violation Guidelines
For additional help with the COVID-19 crisis and make it easier to provide virtual care to patients to minimize in-person office visits, the HHS Office for Civil Rights (OCR) is relaxing HIPAA violations against healthcare practitioners who are serving patients through everyday technologies such as FaceTime or Skype, but not public facing systems such as Facebook Live. In the past, these technologies have not been considered HIPAA-compliant, but you can now use them to evaluate patients. As you know, privacy is always a top concern and while you may not consider having a patient text their photos to you or ask questions via their personal smart phones, you at least have it as a legitimate option if needed.

The spread of COVID-19 is requiring new ways to look at delivering care and virtual services are now more available to help you to minimize bringing the virus into your physical office. Some ways you can use these services to provide care in your office is to screen patients with automated text messages and calls, use virtual visits to triage urgent care and emergency visits, and replace outpatient visits for high-risk patients with compromised immune systems.

To continue providing our valued clients and the medical community with information that can help during the COVID-19 crisis, Kareo is conducting a webinar this Thursday, March 26 at 10 a.m., Pacific. Entitled, Telehealth Coding and Billing Guidance for COVID-19, our in-house billing subject matter expert, Terri Joy, will continue the discussion of billing codes and what you need to know now regarding delivering care in a COVID-19 era. You can register here.

For additional information on Medicare telehealth services, check out a helpful resource here.