Due to COVID-19, new guidelines have been established for telehealth services. Commercial and Medicare, Medicare Advantage Plans, Medicaid and Medicaid Centennial Plans have eased restrictions to allow patients to see their practitioner via telehealth. Below are some important points.

CMS is expanding this benefit on a temporary and emergency basis under the 1135 waiver authority and Coronavirus Preparedness and Response Supplemental Appropriations Act.

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Telehealth Offers a Range of Benefits!

  • Flexible schedule: With telehealth you can have secure, real-time two-way communication with your clients anytime and anywhere. You do not have to be confined to a 9-to-5 schedule. You can conduct sessions during times that best fit your schedule (and your patients).
  • Convenience: You can provide your services from your office, your home, or even while traveling. With telehealth you are no longer constrained by your physical location. You can easily connect with your patients as long as you have an internet connection and a camera.
  • Greater access: Telehealth can make health services more accessible and convenient—increasing treatment outcomes. Patients may also seek care earlier if they have the option to get help without leaving their homes. Additionally, telehealth also gives rural patients and patients with limited mobility increased access to healthcare they may not have had access to otherwise.
  • Increased income: Telehealth gives you the opportunity to offer additional hours in which you may be available. With telehealth, you can schedule appointments at non-traditional hours. This not only allows you to increase your revenue, it also opens access to more potential patients. Additionally, because clients can take appointments anywhere, you’re likely to see fewer no shows.
  • Improved quality: Countless studies over the last decade have consistently shown that telehealth provides quality of care that is on par with traditional in-person services.

Telehealth (also called telemedicine, remote medicine, or online medicine) is a rapidly expanding area. Telehealth’s growing popularity can be attributed to the fundamental benefits it brings to both providers and patients. Our list above just includes a few of these many benefits. However, to gain a better picture of what telehealth has to offer, let’s break down some new policies and regulations.

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Understanding Telehealth Regulations

Medicare Guidelines

New guidelines have recently opened up restrictions for Telehealth regulations for Medicare patients. Rural and site limitations are removed. Telehealth services can now be provided regardless of where the patient is located geographically. This now allows the patients home to be an eligible originating site.

Who Can Provide Telehealth Services?

  • Physicians
  • Nurse Practitioners
  • Physician assistants
  • Nurse-midwives
  • Clinical nurse specialists
  • Certified registered nurse anesthetists
  • Clinical psychologists (CP)
  • Clinical social workers (CSWs) (NOTE: CPs and CSWs cannot bill Medicare for psychiatric diagnostic interview examinations with medical services or medical evaluation and management services. They cannot bill or get paid for Current Procedural Terminology (CPT) codes 90792, 90833, 90836, and 90838).
  • Registered dietitians or nutrition professional

New guidelines allow practitioners to practice across state lines! You can practice in all 52 states!

The Commercial Carriers below have followed Medicare protocol and removed restrictions to Telehealth visits. They have even waived copays to patients in order to encourage tele visits. If you have an NPI number and currently have a contract with the commercial carriers, you can bill and receive reimbursements for telehealth visits!

Commercial Carriers

At the time of this release, this is the most current information we have. As other commercial carriers loosen and update their telehealth guidelines, we will continue to provide the most current information.

CMS Guidelines

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Understanding HIPAA Regulations

A change was made regarding the Health Insurance Portability and Accountability Act (HIPAA) “Effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency.

Notification of Enforcement Discretion for telehealth remote communications during the COVID-19 nationwide public health emergency

HIPAA Guidelines

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How to Implement Telehealth Today

Set up a team that will help facilitate the expedited implementation of telemedicine services and be able to make decisions quickly to ensure launch as soon as possible!

  1. Check with your existing EHR vendor to see if there is telehealth functionality that can be turned on.
    • If so, this allows you to use your patient portal to provide telehealth to your patients.
    • Your patients can access the portal to make telemedicine appointments.
    • If your staff is getting calls from new patients take them. Have your staff register the patient and obtain their email. Train your staff to walk the patient through the patient portal registration to ensure that the patient registers properly.
    • The provider then can conduct telemedicine visits with new patients.
  2. If your existing EHR vendor does not have telehealth functionality
    • Download Google Hangouts
    • Obtain permission from patient to conduct telehealth visit
    • Schedule visit
    • Practitioners can download Google Hangouts on any device i.e. smart phone, laptop, tablets etc.
    • Staff can text an invite from Hangouts to the patient
    • See our guide for clinical reporting guidelines

This is not a complicated process! This can provide replacement revenue immediately!

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Which CPT Codes are Used for Telehealth?

Note: The telemed Place of Service (POS) should be equal to what it would have been had the service been furnished in-person.

*GT and 95 modifiers are used for some commercial plans to indicate services were rendered via synchronous telecommunication. Your billing staff should be aware of these modifiers and how they should be used.

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Valid Telehealth CPT Codes

CY 2020

Code Short Descriptor
90785Psytx complex interactive
90791Psych diagnostic evaluation
90792Psych diag eval w/med srvcs
90832Psytx pt&/family 30 minutes
90833Psytx pt&/fam w/e&m 30 min
90834Psytx pt&/family 45 minutes
90836Psytx pt&/fam w/e&m 45 min
90837Psytx pt&/family 60 minutes
90838Psytx pt&/fam w/e&m 60 min
90839Psytx crisis initial 60 min
90840Psytx crisis ea addl 30 min
90846Family psytx w/o patient
90847Family psytx w/patient
90951Esrd serv 4 visits p mo <2yr
90952Esrd serv 2-3 vsts p mo <2yr
90954Esrd serv 4 vsts p mo 2-11
90955Esrd srv 2-3 vsts p mo 2-11
90957Esrd srv 4 vsts p mo 12-19
90958Esrd srv 2-3 vsts p mo 12-19
90960Esrd srv 4 visits p mo 20+
90961Esrd srv 2-3 vsts p mo 20+
90963Esrd home pt serv p mo <2yrs
90964Esrd home pt serv p mo 2-11
90965Esrd home pt serv p mo 12-19
90966Esrd home pt serv p mo 20+
90967Esrd home pt serv p day <2
90968Esrd home pt serv p day 2-11
90969Esrd home pt serv p day 12-19
90970Esrd home pt serv p day 20+
96116Neurobehavioral status exam
96150Assess hlth/behave init
96151Assess hlth/behave subseq
96152Intervene hlth/behave indiv
96153Intervene hlth/behave group
96154Interv hlth/behav fam w/pt
96160Pt-focused hlth risk assmt
96161Caregiver health risk assmt
97802Medical nutrition indiv in
97803Med nutrition indiv subseq
97804Medical nutrition group
99201Office/outpatient visit new
99202Office/outpatient visit new
99203Office/outpatient visit new
99204Office/outpatient visit new
99205Office/outpatient visit new
99211Office/outpatient visit est
99212Office/outpatient visit est
99213Office/outpatient visit est
99214Office/outpatient visit est
99215Office/outpatient visit est
99231Subsequent hospital care
99232Subsequent hospital care
99233Subsequent hospital care
99307Nursing fac care subseq
99308Nursing fac care subseq
99309Nursing fac care subseq
99310Nursing fac care subseq
99354Prolonged service office
99355Prolonged service office
99356Prolonged service inpatient
99357Prolonged service inpatient
99406Behav chng smoking 3-10 min
99407 chng smoking > 10 min Beha
99495Trans care mgmt 14 day disch
99496Trans care mgmt 7 day disch
99497Advncd care plan 30 min
99498Advncd are plan addl 30 min
G0108Diab manage trn per indiv
G0109Diab manage trn ind/group
G0270Mnt subs tx for change dx
G0296Visit to determ ldct elig
G0396Alcohol/subs interv 15-30mn
G0397Alcohol/subs interv >30 min
G0406Inpt/tele follow up 15
G0407Inpt/tele follow up 25
G0408Inpt/tele follow up 35
G0420Ed svc ckd ind per session
G0421Ed svc ckd grp per session
G0425Inpt/ed teleconsult30
G0426Inpt/ed teleconsult50
G0427Inpt/ed teleconsult70
G0436Tobacco-use counsel 3-10 min
G0437co-use counsel>10min Toba
G0438Ppps, initial visit
G0439Ppps, subseq visit
G0442Annual alcohol screen 15 min
G0443Brief alcohol misuse counsel
G0444Depression screen annual
G0445High inten beh couns std 30m
G0446Intens behave ther cardio dx
G0447Behavior counsel obesity 15m
G0459Telehealth inpt pharm mgmt
G0506Comp asses care plan ccm svc
G0508Crit care telehea consult 60
G0509Crit care telehea consult 50
G0513Prolong prev svcs, first 30m
G0514Prolong prev svcs, addl 30m
G2086Off base opioid tx first m
G2087Off base opioid tx, sub m
G2088Off opioid tx month add 30
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Charting Requirements for Telemed Visits

Below are the charting requirements recommended by the AMA for telemedicine visits.

In the clinical guidelines these are the only things that are required and recommended:

  • Patient name
  • Identification number
  • Date of service
  • Referring physician
  • Consulting physician
  • Provider organization
  • Provider location
  • Patient location
  • Telemedicine order
  • Type of evaluation performed
  • Informed consent, if appropriate (In many telemedicine programs, the referring physician/organization retains the original and a copy is sent to the consulting physician/organization)
  • Evaluation results (In many telemedicine programs, the consulting physician/organization retains the original and a copy is sent to the referring physician/organization)
  • Diagnosis/impression
  • Recommendations for further treatment

Guidelines for the Reporting of Vitals in Telemed

FDA allows expanded use of devices to monitor patients’ vital signs remotely.

  • “Allowing these devices to be used remotely can help health care providers access information about a patient’s vital signs while the patient is at home, reducing the need for hospital visits and minimizing the risk of exposure to coronavirus,” said FDA Principal Deputy Commissioner Amy Abernethy, M.D., Ph.D. “This policy reflects the FDA’s commitment to ease burdens on health care providers and facilities as they face this public health emergency. Such devices include technologies capable of enabling remote interactions to provide crucial information to be used as an adjunctive when health care providers diagnose or treat COVID-19 or co-existing conditions. During this public health emergency, it is imperative that the FDA provide regulatory relief and adapt as the situation warrants to act upon measures to save lives.”

Vitals can be recorded using home devices by the patient or a caregiver.

  • The patient can self-report weight, height, and blood pressure. Which can be used to calculate the patients BMI
  • The provider can note the patient’s health record with the following wording:

“Vitals not recorded due to COVID-19 Emergency”

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New Telehealth Copay Guidelines

Waiver 1135 and the CARES Act allows insurance carriers to reduce or waive copays to help reduce financial strain on the patient and to promote telemedicine! Below is a list of the current copay guidelines for some of the main carriers:

  • Medicare – All copays waived for telehealth
  • Blue Cross – All copays waived for telehealth
  • Aetna - Copays are still applicable
  • United Health Care - Copays are still applicable
  • Presbyterian Health Plan – Copays are still applicable

During the Covid-19 pandemic, providers can now waive and reduce copays in the following instances:

  • A physician or other practitioner reduces or waives cost-sharing obligations (i.e., coinsurance and deductibles) that a beneficiary may owe for telehealth services furnished consistent with the then-applicable coverage and payment rules.
  • The telehealth services are furnished during the time period subject to the COVID-19 Declaration.5
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Telemedicine Workflow

Telemedicine workflow
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What additional equipment would I need to purchase?

None! With new regulations and loosened HIPAA compliance regulations you can use readily assessable programs such as:

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What does the patient need to participate in telemedicine?

  • Desktop (camera required)
  • Laptop (camera required)
  • Smartphone
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How will I be reimbursed for telehealth visits?

Some states have parity laws that require insurance companies to reimburse at the same rate as in-person care for services provided.

States with parity laws:

  • Alaska
  • Arizona
  • Arkansas
  • California
  • Colorado
  • Connecticut
  • Delaware
  • District of Columbia
  • Georgia
  • Hawaii
  • Indiana
  • Kentucky
  • Louisiana
  • Maine
  • Maryland
  • Michigan
  • Minnesota
  • Mississippi
  • Missouri
  • Montana
  • Nevada
  • New Hampshire
  • New Mexico
  • New York
  • Oklahoma
  • Oregon
  • Rhode Island
  • Tennessee
  • Texas
  • Vermont
  • Virginia
  • Washington

States without parity laws:

  • Alabama
  • Florida
  • Idaho
  • Illinois*
  • Iowa*
  • Kansas
  • Massachusetts
  • Nebraska
  • New Jersey*
  • North Carolina*
  • North Dakota
  • Ohio*
  • Pennsylvania*
  • South Carolina
  • South Dakota
  • Utah
  • West Virginia
  • Wisconsin
  • Wyoming

*Proposed legislation to change law.

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How can I take advantage of telemedicine in the wake of patient appointment cancelations due to COVID-19?

Instruct reception staff who receive cancelation calls to encourage your patient to take advantage of a telemedicine visit!

Patient: Hi, this is Mr. Jones and I am calling today to cancel my upcoming appointment.

Staff: Mr. Jones it is very important that you keep your appointment. Dr. Smith has added telemedicine services to our practice. You can keep your appointment and we can set it up so that you can see Dr. Jones via a link we can send you. Your appointment can be done on the internet and Dr. Jones can be seen with a couple of setup steps and it is virtually seamless.