There’s a lot you need to know about telehealth. That’s why Medical Office Manager is offering a webinar, Telehealth—What Managers Need to Know, on April 6. It’s free to Medical Office Manager members.
Presenter Jen Bell of Karen Zupko and Associates will give you the tools and knowledge you need to comply with new telehealth regulations. Meanwhile here is Jen’s update on telehealth changes to early 2022.
POS 10 Telehealth Provided in Patient’s Home
- Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology.
- Home may be defined to include temporary lodging (hotels, homeless shelters) and patient travels of short distance from the exact home location.
- Added for insurance industry use—MEDICARE DOES NOT RECOGNIZE POS 10 at this time. Effective Jan. 1, 2022
- Implementation date of April 4, 2022. Medicare will not deny POS 10, but will treat it as POS 02.
POS 02 Telehealth Provided Other than in Patient’s Home
- Patient is not located in their home when receiving health services or health related services through telecommunication technology.
- A location such as a hospital or other facility
- During the PHE, POS 02 is used for providers who do not normally see patients in an office setting.
- For use by all providers after the PHE or as directed by the payor during the PHE.
Modifier 93 Synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system
- Used for real-time, audio-only medically necessary E/M visits.
- Communication during the telemedicine service must meet the key components and/or requirements of the same service when rendered via a face-to-face interaction.
- Medicare has not given guidance on use of this modifier (as of Jan. 19, 2022).
- Check with commercial payors for guidance on usage of this modifier.
Other Medicare modifiers (specifically for telehealth mental health)
- FQ – A telehealth service was furnished using real-time audio-only communication technology
- FR – A supervising practitioner was present through a real-time two-way, audio/video communication technology
- Medicare will give instructions on the use of these modifiers at a future date.
Good News
- Medical nutrition therapy (MNT) and diabetes self-management training (DSMT) may be provided via telehealth by registered dieticians and nutrition professionals as distant site providers.
- Behavioral health wins: no geographical restrictions, patient’s home can be an originating site, and telephone calls are payable under certain conditions.
The Not So Good News
- Not allowing virtual supervision after the PHE ends. CMS will possibly revisit virtual supervision at another time.
- CMS declined to add telephone only codes 99441-99443 to the permanent list (except for behavioral health).
CMS Approved Telehealth Listing Updates
CMS created different categories for the Telehealth approved listing to represent three different types of approval categories. For 2022 they have added codes and extended Category 3 codes until December 21, 2023. A word of caution here – if the PHE ends before Dec. 31, 2023, category 3 codes must still meet geographic restrictions and the patient’s home will no longer be an eligible originating site (except for behavioral health).
- Category 1 – 109 codes that are permanently approved to stay on the list after the end of the PHE
- Category 2 – 99 codes that are temporarily approved until the end date of the current PHE
- Category 3 – 63 codes that are temporarily approved until Dec. 31, 2023
A complete updated listing of the approved codes for telehealth can be found at:
https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes
Telephone Only Telehealth Visits
CMS confirmed that audio-only (telephone call) visit coverage for telehealth visits (99441-99443) will end at the end of the PHE. There are other non-telehealth designated audio-only services, but telephone calls will no longer be considered for payment as telehealth visits.
Originating Site Restrictions
CMS also confirmed that except for behavioral health services, geographic flexibilities will stop at the end of the PHE. This means the patient’s home will no longer be a billable location for telehealth. There are a few exceptions. The patient’s home can be an originating site for behavioral health services, qualifying patients receiving home dialysis with ESRD, and certain patients who are receiving opioid or substance abuse treatment.
Virtual Direct Supervision
In 2021 CMS clarified the definition of virtual direct supervision as audio with video, not audio only communication with a patient. And they confirmed that virtual direct supervision is approved through the end of the year that PHE has ended. In 2022 CMS finalized that virtual supervision will stop at the end of the PHE, but it may be considered again in the future at some point in time.
Virtual Check-In
In 2022 CMS permanently adopted the virtual check-in code G2252 for providers who bill E/M services (e.g., MD, DO, PA, NP)
G2252 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; 11-20 minutes of medical discussion
All other Virtual Check-In codes remain available for use in 2022.
- Online Digital Assessment
- As a reminder, the G2061-G2063 code set was deleted in 2021 by CMS. All providers who do not bill E/M services are now instructed to use codes 98970-98972 for online digital assessments.
- Originating Site Reimbursement
- Q3014 Originating site reimbursement increased in payment for 2022 to $27.59 (from $27.02). Remember, this is the code for hosting the session where the patient is located. This code is not billed by the provider at a distant site who is billing separately for the telehealth visit.
- Behavioral health has additional permanent flexibilities:
- General principles of documentation still apply
- It’s a shift, not a new standard
- Reason for service is still necessary
- Don’t overgeneralize the note
- Remember to document the rationale in your thinking
- Beware of note bloat
- Don’t copy & paste – still a no-no
- More documentation doesn’t always mean a higher code
- Be intentional with documenting key information
- Key elements for telehealth service documentation:
- Consent
- Patient and provider location
- Names of who is participating in the call
- Audio with video or audio only
- Date the patient was last seen
- Time or Medical Decision Making
Currently there are several bills in Congress regarding telehealth that have passed through the Senate or House of Representatives awaiting next steps.
Telehealth has been brought to the forefront and utilized out of necessity. This has created a lot of attention and scrutiny at both the federal and state levels. There is a vested interest in promoting telehealth and creating healthy broadband infrastructures to increase access for all Americans, especially those in underserved areas throughout the country.
As a result, CMS is forming a “commissioned study” to analyze claims data to
- Look at the impact of temporary expansion of telehealth codes
- To have feedback for future rulemaking
- To mitigate and prevent fraud, waste, and abuse
Telehealth resources
- KZA Telehealth Solutions Center
https://www.karenzupko.com/KZA-telehealth-solution-center - ATA
https://www.americantelemed.org/Center for Connected Health Policy
https://www.cchpca.org - National Consortium of Telehealth Resources Center
https://www.telehealthresourcecenter.org/
