CMS Telehealth Coding Presents New Challenges

cms telehealth coding

As our recent article on Telehealth indicated, the Centers for Medicare and Medicaid Services (CMS) officially expanded its payment protocol to cover Medicare telehealth services in March of 2020. This meant that providers had greater flexibility in providing treatment and visits, with Medicare covering treatments that they previously would not have.

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Telemedicine Services Are Here to Stay Thanks to COVID-19, Shows Telehealth Billing Statistics

telehealth billing

The number of telehealth visits via real-time audio-video communication, as well as audio-only phone calls, skyrocketed in 2020, telehealth billing statistics show, due to the outbreak of SARS-CoV-2 and stay-at-home orders nationwide. Nearly half (43.5%) of Medicare primary visits were done via telehealth in April, compared to just 0.1% in February prior to the public health emergency (ASPE-HHS, 2020).

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Telehealth Resource Center for Revised PHE Coding & Billing Policies Due to COVID-19

telehealth resource center

The Center for Medicare & Medicaid Services (CMS) expanded the payment guidelines for professional telehealth services provided to Medicare beneficiaries during the Public Health Emergency (PHE) declared for COVID-19 (CMS, 2020). The temporary protocol expansion was deemed necessary to aid healthcare reimbursement, and will be active only during the PHE. To keep coders and auditors up-to-date on the expanded services and reimbursement guidelines, YES HIM Consulting has gathered all the latest updates to form a telehealth resource center.

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Telemedicine Guidelines & COVID-19: Coding in Response to the 1135 Waiver Authority

telemedicine guidelines

Due to the stay-at-home orders put in effect by state governors and the highly contagious COVID-19 virus, CMS has expanded coverage for its Medicare recipients through the use of telemedicine (CMS, 2020). According to CMS, “The benefits are part of the broader effort by CMS and the White House Task Force to ensure that all Americans – particularly those at high-risk of complications from the virus that causes the disease COVID-19 – are aware of easy-to-use, accessible benefits that can help keep them healthy while helping to contain the community spread of this virus” (2020).

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CMS Increases List of Payable Medicare Telemedicine Services

Telemedicine

Adapting to the influx of telehealth services in response to the COVID-19 outbreak, CMS has adjusted the “List of services payable under the Medicare Physician Fee Schedule when furnished via telehealth” in order to provide as much support and care as possible (2020). In addition, CMS issued updated criteria for risk adjustment of Medicare telemedicine services, as well as guidelines on how to bill for telemedicine.

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CMS Clarifies Risk Adjustment Criteria for Coding Telehealth Services

Coding Telehealth

CMS clarified on April 10, 2020, that the submission of ICD-10-CM diagnoses codes for Risk Adjustment are permitted from coding telehealth services as long as it meets the set criteria (i.e. inpatient, outpatient, or professional service and from a face-to-face encounter) (CMS, 2020). CMS is stating that telehealth services can meet the face-to-face requirement “when the services are provided using an interactive audio and video telecommunications system that permits real-time interactive communication” (2020). From a medical coding and billing standpoint, the change in the telehealth services criteria for risk adjustment is causing updates to how these services are billed.

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