Review the Temporary Physician-Based Telehealth Policies & Regulatory Revisions for COVID-19
Due to the ongoing PHE regarding the 2019 Novel Coronavirus (COVID-19) outbreak, CMS has issued an interim final rule (IFC). This is to provide guidance on the updated telehealth policies and other services (CMS, 2020).
Updates to Direct Supervision
The current PHE has relaxed many supervision requirements, allowing for supervision to be provided through audio/video telecommunications. This presently includes, but is not limited to, inpatient rehabilitation facilities (IRFs), inpatient and outpatient hospital services, and teaching facilities. The IFC update also includes non-surgical extended duration therapeutic services (NSEDTS), as well as infusions. Additionally, CMS has updated direct supervision to extend to pulmonary rehabilitation, cardiac rehabilitation, and intensive cardiac rehabilitation services. This allows for the virtual presence of the physician to be suitable. CMS has also added Home Health and Hospice services, indicating that it may be safer for provider and patient (2020).
Updates to Telehealth Policies
CMS has made a change to professional claims for Place of Service in the telehealth policies. During the PHE, coders will not use the place of service (POS) 02 Telehealth. Instead, providers billing the CMS-1500 may use the POS that would have been used had there been no PHE, and the service was completed face-to-face with the patient. For example, providers would bill POS 11 if the provider would have seen the patient in the clinic. As long as the emergency lasts, coders should append the appropriate telehealth modifier to the claim. These include: 95 – Synchronous Telemedicine Service Rendered via a Real-Time Interactive Audio and Video Telecommunications System; G0 – Telehealth services for diagnosis, evaluation, or treatment, of symptoms of an acute stroke; GT – Provided by interactive audio/video telecommunication systems (Critical Access Hospital (CAH) Method II only); GQ – Via asynchronous telecommunications system (Alaska & Hawaii demonstration project only).
According to the AMA, “In response to efforts by organized medicine, CMS will be increasing payments for audio-only telephone visits between Medicare beneficiaries and their physicians to match payments for similar office and outpatient visits. This would increase payments for these services from a range of about $14-$41 to about $46-$110, and the payments are retroactive to March 1, 2020” (2020).
CMS has further expanded telehealth policies and procedures. They now include E/M services for emergency department visits, critical care services, nursing facilities, End State Renal Disease (ESRD) services, psychological/neuropsychological testing, and radiation treatment management (CMS, 2020). Additionally, the IFC added therapy services to the telemedicine policy; however, the therapists who generally provide these services have not been approved to utilize telehealth. Physical therapy (PT), occupational therapy (OT), and speech language pathology (SP) must be provided by a physician or non-physician practitioner (NPP), such as a nurse practitioner (NP) or physician assistant (PA).
Update to Homebound Status
Also, CMS has updated the definition of “homebound”. This is to reflect that the physician may now advise the patient to stay home because of a confirmed or suspected COVID-19 diagnosis, or if the patient has an underlying condition making them more susceptible to contract COVID-19. In addition to other changes in telehealth policy, the Office for Civil Rights (OCR) at the Department of Health and Human Services (HHS) is relaxing the enforcement of certain regulations covered under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Health Information Technology for Economic and Clinical Health Act (HITECH) regarding security and confidentiality (HHS, 2020).
Our articles on recent telehealth updates, “Medicare Telehealth Services Now Included in Expanded Payment Protocol,” and “CMS Guidelines for Telehealth Coding & Billing During PHE,” document everything medical coders need to know to stay compliant with the new telehealth policies and regulatory revisions during the COVID-19 outbreak. Our upcoming article will explain the Medicare Fee-for-Service (FFS) response to the Coronavirus.
Review our additional articles regarding the COVID-19 telemedicine updates, which discuss 1135 waiver and coding, virtual services and telemedicine providers, and the Medicare telemedicine reimbursement guidelines, on the YES Blog.
Does your organization need coding support or consulting services, especially with telehealth policy updates circulating? Contact YES HIM Consulting’s team of coding consultants to discuss your solutions today!
Do you need to learn how to code the COVID-19 vaccines or telehealth services? Enroll in the latest CPT Hot Topics learning series from YES HIM Education. This series dives into the HCPCS/CPT codes and guidelines for COVID-19 monoclonal antibodies, COVID-19 vaccines, and telehealth. We will also discuss payment policies for all three topics.