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CMS GUIDELINE ON TELEHEALTH SERVICES

INSIGHTS ON TELEHEALTH

 

During this period of global lockdown due to COVID-19, providing health services is a challenge. Yet with the boon of technology, patients can get treated through online videoconferencing/telephone/audio conferencing, which is referred to as telehealth services. United States and some other countries have already implemented these services since several years ago. However, the current pandemic situation has encouraged other countries too to follow telehealth services, since this is the best option to stay at home and get medical advice from the doctor, thereby following Social distancing too.

 

Inspite of many restrictions in the usage of communication platform, CMS  wanted the telehealth services to be carried out via a HIPPA compliant platform. But right now, owing to the crisis, many payers including Medicare have started allowing telehealth services through Face Time, Zoom, Skype of any other platform, other than open platforms like Facebook and Tik Tok.

 

TELEHEALTH EXPANSION MEASURES DURING COVID-19 EMERGENCY IN THE USA

 

CMS is expanding this facility on a temporary and emergency basis under the 1135 waiver authority and Coronavirus Preparedness and Response Supplemental Appropriations Act. These benefits are part of the bigger efforts by CMS and the White House Task Force to ensure that all Americans, mainly those at high risk of complications from the Corona virus, become aware of the easy-to-use, accessible facilities that can keep them safe and healthy, while aiding to constrict the community spread of this virus. Under this new waiver 1135, Medicare will be paying for office, hospital and other visits furnished via telehealth across the country, including patients’ places of residence starting from March 6, 2020.

 

VIRTUAL SERVICES – TYPES

 

  • Telehealth visits
  • Virtual Check-ins
  • E-visits

 

Telehealth visits

 

  • Medicare will provide payment for professional services rendered to beneficiaries in all areas of the country in all settings.
  • Similar to in-person visits and the rates remain as same for the regular visits.
  • Services started effectively from March 6, 2020 and will be served during the COVID-19 Public Health Emergency, whilst Medicare makes the payment for Medicare telehealth services furnished exclusively for patients in broader situations.
  • Effective for services starting March 6, 2020 and for the duration of the COVID-19 Public Health Emergency, Medicare will make payment for Medicare telehealth services furnished to beneficiaries in any healthcare facility and in their home, if they have to travel to different originating sites such as the Doctor’s office or hospital or in need of skilled nursing facility.
  • To the extent the 1135 waiver requires an established relationship, HHS will not conduct audits to ensure that such a prior relationship existedfor claims submitted during this public health emergency.
  • The Medicare coinsurance and deductible would generally apply to these services. However, the 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.

 

Virtual Check-ins

 

  • Virtual check-in services can only be reported when the billing practice has an established relationship with the patient.
  • This is not limited to only rural settings or certain locations.
  • Individual services need to be agreed to by the patient; however, practitioners may educate beneficiaries on the availability of the service prior to patient agreement.
  • HCPCS code G2012: Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.
  • HCPCS code G2010: Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment.
  • Virtual check-ins can be conducted with a broader range of communication methods, unlike Medicare telehealth visits, which require audio and visual capabilities for real-time communication.

 

E-Visits

 

  • These services can only be reported when the billing practice has an established relationship with the patient.
  • This is not limited to only rural settings. There are no geographic or location restrictions for these visits.
  • Patients communicate with their doctors without going to the doctor’s office by using online patient portals.
  • Individual services need to be initiated by the patient; however, practitioners may educate beneficiaries on the availability of the service prior to patient initiation.
  • The services may be billed using CPT codes 99421-99423 and HCPCS codes G2061-G206, as applicable.
  • The Medicare coinsurance and deductible would generally apply to these services.

 

Medicare Coverage Information

 

Telehealth Services

 

To enable services to continue while lowering exposure risk, clinicians can now provide the following additional services by telehealth:

 

  • Emergency Department Visits, Levels 1-5 (CPT codes 99281-99285)
  • Initial and Subsequent Observation and Observation Discharge Day Management (CPT codes 99217- 99220; CPT codes 99224- 99226; CPT codes 99234- 99236)
  • Initial hospital care and hospital discharge day management (CPT codes 99221-99223; CPT codes 99238- 99239)
  • Initial nursing facility visits, All levels (Low, Moderate, and High Complexity) and nursing facility discharge day management (CPT codes 99304-99306; CPT codes 99315-99316)
  • Critical Care Services (CPT codes 99291-99292)
  • Domiciliary, Rest Home, or Custodial Care services, New and Established patients (CPT codes 99327- 99328; CPT codes 99334-99337)
  • Home Visits, New and Established Patient, All levels (CPT codes 99341- 99345; CPT codes 99347- 99350)
  • Inpatient Neonatal and Pediatric Critical Care, Initial and Subsequent (CPT codes 99468- 99473; CPT codes 99475- 99476)
  • Initial and Continuing Intensive Care Services (CPT code 99477- 994780)
  • Care Planning for Patients with Cognitive Impairment (CPT code 99483)
  • Psychological and Neuropsychological Testing (CPT codes 96130- 96133; CPT codes 96136- 96139)
  • Therapy Services, Physical and Occupational Therapy, All levels (CPT codes 97161- 97168; CPT codes 97110, 97112, 97116, 97535, 97750, 97755, 97760, 97761, 92521- 92524, 92507)
  • Radiation Treatment Management Services (CPT codes 77427)
  • Licensed clinical social worker services, clinical psychologist services, physical therapy services, occupational therapist services, and speech language pathology services can be paid for as Medicare telehealth services.

 

Virtual Check-Ins & E-Visits

 

  • Additionally, clinicians can provide virtual check-in services (HCPCS codes G2010, G2012) to both new and established patients. Virtual check-in services were previously limited to established patients.
  • Licensed clinical social workers, clinical psychologists, physical therapists, occupational therapists, and speech language pathologists can provide e-visits. (HCPCS codes G2061-G2063).
  • A broad range of clinicians, including physicians, can now provide certain services by telephone to their patients (CPT codes 98966 -98968; 99441-99443) 
Remote Patient Monitoring
  • Clinicians can provide remote patient monitoring services to both new and established patients. These services can be provided for both acute and chronic conditions and can now be provided for patients with only one disease. For example, remote patient monitoring can be used to monitor a patient’s oxygen saturation levels using pulse oximetry. (CPT codes 99091, 99457-99458, 99473- 99474, 99493-99494)

 

Removal of Frequency Limitations on Medicare Telehealth

 

To better serve the patient population that would otherwise not have access to clinically appropriate in-person treatment, the following services no longer have limitations on the number of times they can be provided by Medicare telehealth:

 

  • A subsequent inpatient visit can be furnished via Medicare telehealth, without the limitation that the telehealth visit is once every three days (CPT codes 99231-99233);
  • A subsequent skilled nursing facility visit can be furnished via Medicare telehealth, without the limitation that the telehealth visit is once every 30 days (CPT codes 99307-99310)
  • Critical care consult codes may be furnished to a Medicare beneficiary by telehealth beyond the once per day limitation (CPT codes G0508-G0509).