The Centers for Medicare and Medicaid Services (CMS) has expanded Medicare’s telehealth benefits during the COVID-19 public health emergency under the 1135 waiver authority. Effective for dates of service starting March 6, 2020, the new telehealth policy will allow physicians to receive reimbursement for providing telehealth services to Medicare patients across the country, with fewer restrictions. Clinicians can provide Medicare telehealth services to new or established patients. As coverage, billing, and coding are continuously evolving, medical billing outsourcing is a practical option for physicians to get paid for services related to the novel coronavirus.

There are three basic types of Medicare telehealth services: Medicare telehealth visits, virtual check-ins and e-visits.

  • The same as in-person visits, Medicare telehealth visits require real-time communication between providers and patients using both audio and video
  • Virtual check-ins are brief communications between physicians and patients, such as text messaging.
  • E-visits are delivered through a patient portal, which requires providers to have a pre-existing relationship with a Medicare beneficiary.

Let’s take a look at the key points relating to telehealth expansion for Medicare patients during the COVID-19 crisis:

  • Removal of Restrictions: Prior to the current waiver, healthcare providers had to meet the following Medicare requirements for telehealth services:
    • The patient receiving telehealth services must be located at one of eight “originating sites”, which include hospitals, physicians’ offices, and rural health clinics.
    • The originating site must meet certain geographic requirements, which essentially restricted the provision of telehealth to patients in rural areas.
    • Medicare telehealth visits were restricted to established patients.

Under the Telehealth Services During Emergency Periods Act which came into effect with the coronavirus public health crisis, telehealth has been expanded. Many restrictions surrounding telehealth coverage for Medicare beneficiaries have been removed. Under the new telehealth policy:

  • Providers will be reimbursed for telehealth services provided to patients from within their own home.
  • Telehealth services can be provided in a variety of settings, including nursing homes, assisted living facilities, hospital outpatient departments, and more.
  • Besides physicians, a wide range of providers such as nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologists, registered dieticians, nutritional professionals, and licensed clinical social workers can provide Medicare telehealth services.
  • Patients can use a wide range of communication methods, including telephone, smart phone and interactive apps, to interact face-to-face with their clinician.
  • The type of visit that Medicare patients may receive via telecommunication methods with their provider include common office visits, mental health counselling, preventative health screening, and more.
  • Virtual check-ins can be provided for both new and established Medicare patients. Previously these services could be provided only to patients that had an established relationship with their physician.
  • Virtual check-ins can conducted using communication technology modalities such as synchronous discussion over a telephone or exchange of information through video or image.
  • CMS now allows providers the “flexibility” to waive or reduce cost-sharing amounts, such as co-pays and deductibles, for Medicare patient visits during the COVID outbreak.
  • Additional Telehealth Services: CMS will now pay for more than 80 additional services provided via telehealth, including emergency department visits, initial nursing facility and discharge visits, and home visits, which must be provided by a clinician that is allowed to provide telehealth. Important additional services and their CPT codes:
    • 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)
  • Removal of Frequency Limitations on Medicare Telehealth: Another CMS flexibility to fight COVID-19 is the removal of frequency limitations on Medicare telehealth. This measure is aimed at meeting the needs of patients who would otherwise not have access to clinically appropriate in-person treatment. With the removal of frequency limitations, 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)

On March 30, 2020, CMS announced further actions being taken to help providers address patients’ needs during the COVID -19 pandemic. This includes new guidance for ambulatory surgery centers, community mental health centers, outpatient physical therapy and other settings of care. The guidance provides information on appropriate action to take to address potential and confirmed COVID-19 cases including discussions on recommendations to mitigate transmission such as screening, restricting visitors, and cleaning and disinfection and possible closures.

These flexibilities will increase access to telehealth in Medicare and allow patients to get care from physicians and other clinicians while keeping patients safe at home. As providers focus on ensuring that patients get the best care, they can rely on outsourced medical billing and coding services to submit accurate claims and get paid faster.

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