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TELEHEALTH

Public health emergency jumpstarts remote care

From video chats to relaxation of state licensing requirements, the coronavirus pandemic has accelerated the adoption of remote and virtual healthcare services. Here is an update from CMS:

Medicare Telehealth Visits: Effective for services starting March 6, 2020, and for the duration of the COVID-19 Public Health Emergency (PHE), Medicare will make payments for Medicare telehealth services furnished to patients in broadened circumstances. During the PHE, clinicians can use popular applications that allow for video chat such as Apple FaceTime and Skype, thanks in part to enforcement discretion by the HHS Office of Civil Rights. Clinicians who seek additional privacy protections for telehealth while using video communication products should provide such services through technology vendors that offer HIPAA business associate agreements (BAAs) with their video communication products. In addition, clinicians may utilize telephone without video for other communication technology-based services.

  • Patients may be either a new or established patient.
  • These visits are the same services as would be provided during in-person visit and are paid at the same rate as in-person visits.
  • The patient may be located in any geographic location (not just those designated as rural), in any healthcare facility, or in their home.
  • The Medicare coinsurance and deductible would generally apply to these services; however, the HHS Office of the Inspector General is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.
  • Common telehealth CPT and HCPCS codes include: 99201-99215: Office or other outpatient visits
  • G0425-G0427: Telehealth consultations, emergency department or initial inpatient
  • G0406-G0408: Follow up inpatient telehealth consultations furnished to beneficiaries in hospitals or skilled nursing facility (SNF)

In a case where two-way audio and video technology required to furnish a Medicare telehealth service might not be available, there are circumstances where prolonged, audio-only communication between the practitioner and the patient could be clinically appropriate yet not fully replace a face-to-face visit.

For the duration of the PHE for the COVID-19 pandemic, Medicare will make separate payment for audio-only visits described by CPT codes 98966-98968 and CPT codes 99441-99443 as outlined on page 125 in the Interim Final Rule with Comment.

Virtual Check-ins:  New or established Medicare patients may have a brief communication service with practitioners from wherever they are located, including in their home, via a number of communication technology modalities including synchronous or real-time discussion over a telephone or exchange of information through video or image. CMS expects that these virtual services will be initiated by the patient; however, practitioners may need to educate beneficiaries on the availability of the service prior to patient initiation. Medicare pays for these “virtual check-ins.”

  • This is NOT limited to only rural settings or certain locations, during the PHE or otherwise.
  • Individual services need to be initiated by the patient; however, practitioners may educate beneficiaries on the availability of the service prior to patient initiation.
  • 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 a new or 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 a new or 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.

E-visits:  These visits use an online patient portal. In all types of locations including the patient’s home, and in all areas (not just rural), new or established Medicare patients may have non-face-to-face patient-initiated communications with their doctors or other practitioners. These services are not a substitute for an in-person visit, but are exchanges with a practitioner online through a patient portal.

• 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.

Common telehealth CPT and HCPCS codes include:

o CPT codes 99421-99423

o HCPCS codes G2061-G2063.

An additional measure is temporarily waiving Medicare and Medicaid’s requirements that physicians and non-physician practitioners be licensed in the state where they are providing services in order to contribute relief efforts.

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