QUESTION: The telehealth rules indicate the service must be patient initiated. What does this mean? We are a pulmonology specialty group and are considering seeing new patient referrals and established patients by Skype. How can the new patient visits meet the office visits’ exam requirements?
Question from Detroit, MI Subscriber
ANSWER: CMS included the patient-initiated requirement to discourage practices from soliciting telehealth services. Medicare specifically did not want their coverage to encourage practices to market that they now offer telehealth services — office visits by audio and video (Skype, Zoom for Healthcare).
Do this: In your appointment scheduling and reminders, you can give patients the option of asynchronous communication – You have availability by telehealth using a two-way audio-video service. Explain that both the patient and the doctor will be able to see each other.
Watch out: Auditors will be examining telehealth claims in the summer of 2020. The below scenarios will test your skills. If you get the answers wrong or have other circumstances to resolve to ensure your coding and billing will stand up to scrutiny, turn to nationally recognized coding expert and educator, Leonta Williams, MBA, RHIA, CCS, CCDS, CPC, CPCO, CEMC, CHONC, CRC. By attending her upcoming session, “CMS NEW Telehealth COVID-19 Rule: Get Paid for Virtual Care Services” you’ll get the latest CMS rules on telemedicine coverage during COVID-19.
Scenario 1: Pulmonary referrals and follow-ups are perfect candidates for audio-video telehealth services. The physician himself must have the conversation with the patient on the phone or through the audio-video link. Medicare is covering telehealth office visits for both established and new patients. Established patient visits require two of the three key components: history, examination, and medical decision-making. You can bill the established patient visit based on history and medical decision-making or two of the three components.
Surprise: A telehealth service can also meet the new patient visit additional requirement of an examination. Some examination can be done without laying hands on the patient. Observation can be done through video, and sometimes just through audio. A physician can observe skin tone, abnormal movements, respiratory effort and many other exam elements without being able to necessarily touch the patient. A complete Psychiatric exam can be accomplished through talking with the patient.
Scenario 2: A patient calls in with complaint of dysuria. The physician documents the complaint (Duration, Timing) and further asks questions about fever, nausea and vomiting (Constitutional and Gastrointestinal Review of Systems). He also reviews the patient’s Past Medical History and Allergies. Based on her previous history, he suspects that the patient has a urinary tract infection and orders an antibiotic.
Scenario 3: A patient with asthma calls in with an exacerbation – the physician can actually hear the patient wheezing over the telephone – that would be documented as a problem-focused examination.
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