Due to the COVID-19 pandemic, Congress and the Centers for Medicare & Medicaid Services (CMS) have dramatically expanded coverage and reimbursement of telehealth services. CMS aimed to make health care available to Medicare beneficiaries to keep both providers and patients safe during the Public Health Emergency (PHE). Some of the updates you may need to know about CMS telehealth reimbursement and telehealth services include audio-only services, changes to remote physiologic monitoring services, telehealth reimbursement for outpatient and home settings, and more, as discussed below.
Although many professionals are aware that telephone therapy or audio-only digital connections are reimbursable by CMS, they may not know that as with any healthcare treatment, medical necessity is the overarching criterion for each telephone visit. The integrity of the visit, clinical relevance, intent, and documentation requirements remain the same for telephone treatment as it does for in-person care delivery. CMS has also increased the payment schedule for Telephone E/M codes 99441, 99442, and 99443. Real-time audio and video are needed for telehealth CPT codes 99201-99215 and cannot be billed for the telephone only E/M. The reader may want to be aware that other insurers may not reimburse for such services. Checking with the telehealth reimbursement source is always advisable.
Non-Physician Practitioner Utility Modifications
Previously, diagnostic testing was only reimbursable if performed by a physician. Now CMS permits additional providers to offer telehealth services like brief online assessment and management services, virtual check-ins, and remote evaluations. There are new codes for these services, and licensed clinical social workers, clinical psychologists, physical therapists, occupational therapists, and speech-language pathologists can now bill for their Medicare telehealth services. However, practitioners must still adhere to applicable state law practice and licensure requirements when performing telehealth services.
Opioid Treatment Programs Periodic Assessments Provision via Telephone
CMS allows Opioid Treatment Programs (OTP) periodic assessments to be provided through two-way interactive audio-video communication technology. In cases where beneficiaries do not have access to two-way audio-video communications technology, regular assessments can be provided using audio-only telephone calls and making sure that all other applicable requirements are met. The providers should use their clinical judgment to determine whether they can adequately perform the periodic assessment with audio-only phone calls. If not, they should perform the assessment using two-way interactive audio-video communication technology or in-person as clinically appropriate. Regardless of the format used, the OTP should document the reason for the assessment and the substance of the assessment in the medical record.
Changes to Remote Physiologic Monitoring Services
Previously, remote patient monitoring (RPM) service could not be reported for monitoring of fewer than 16 days during a 30-day period. Now CMS allows RPM services to be reported for periods of time that are fewer than 16 days out of 30 days, but no less than 2 days, as long as the other requirements for billing the code are met. The consent to receive RPM services can be obtained at the delivery time of RPM services. A medical device should be provided to a patient for RPM services, and the data must be collected automatically and transmitted rather than self-reported. Only physicians and NPPs who are eligible to furnish E/M services can bill RPM services.
Below are a few other issues that are currently modified by CMS.
Direct Supervision by Interactive Telecommunications Technology
Direct supervision typically means in-person supervision. To control infection exposure risk to the patient or practitioner, CMS allows direct supervision to be provided using real-time, interactive audio and video technology by revising the definition of “direct supervision” to include virtual presence. CMS will continue allowing virtual supervision through the later of the end of the calendar year in which the PHE ends or December 31, 2021.
Telehealth Reimbursement for Outpatient and Home Settings
CMS finalized that hospitals can now bill for telehealth services provided by hospital-based physicians to patients registered as hospital outpatients. The home-based temporary services provided by the department of the hospital are also included. It is a requirement for providers to document the reasons for the visit in the patient’s medical record. The hospitals can bill for both the distant site provider fee and the originating site facility fee for hospital-based practitioners’ telehealth services, even for patients at home.
Quality Provisions of Payment
CMS postponed the implementation of the MIPS (Merit-Based Incentive Payment System) till 2022 instead of 2021. The actual aim behind the Merit-Based Incentive Payment System Value Pathways is to decrease the administrative burden or the complexity linked with the MIPS and the program’s development. Another objective is to improve the performance threshold from 45 points for the 2020 performance year to 50 points for 2021,10 points less than the 60-point threshold finalized for 2021.
Using Time or MDM
CMS allowed for the E/M level selection for office/outpatient E/M services provided through telehealth based on medical decision-making or time. The times in the public use file do not always align with the times included in the office/outpatient E/M code descriptors, confusing the physician. CMS updated guidelines resolved this confusion by clarifying that the times listed in the CPT code descriptor should be used.
Telehealth CPT Codes
On a side note, the CMS developed new telehealth CPT codes to meet the ever-expanding needs of telehealthcare for the patients, which now include over 80 codes in total. The complete list is available on the CMS website.
Annual Patient Consent
Previously, annual patient consents were required before starting telehealth visits. These requirements have been eliminated. Practitioners can collect informed consent as they deem appropriate.
TBHI sends weekly updates on issues related to reimbursement, legislation, and clinical issues as they surface. If you are delivering telehealth now, it behooves you to stay informed as the landscape changes rapidly and encourages your colleagues to do so too. You can count on TBHI to keep you current and offer you timely and accurate telehealth professional training.
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