If you’re curious about where you stand in terms of telehealth claim compliance, the OIG has a new tool that may help you sort things out. By using the government’s Telehealth Toolkit, you can evaluate how payers are reviewing telehealth claims and shore up any issues that may exist among your own.
Check out a few key strategies that can help you assess the Telehealth Toolkit and use it to your advantage.
Check the Five Key Payer Analysis Areas
As part of the toolkit, the OIG advises payers to review claims data for the following five benchmarks. Below, review what they are so you can follow along and avoid payer scrutiny before it starts.
1. Review Program Policies
What the toolkit suggests: In this step, payers are advised to familiarize themselves with the payment and coverage policies for telehealth claims.
How practices can react: This means your practice should do the exact same thing. Even if you think you know the rules around telehealth claims, remember that payers change their policies frequently, and if you aren’t using the most up-to-date data, you could be billing incorrectly.
2. Collect Telehealth Claims Data
What the toolkit suggests: In step two, payers are advised to identify claims for telehealth services and then to analyze them for such identifiers as place of service codes, modifiers, CPT codes and more.
How practices can react: Now is the time to shore up your claims and confirm that you’re reporting telehealth services using the most recent CPT and ICD-10-CM codes. For instance, although you may have been performing your telehealth visits over the phone in the past, perhaps you transitioned to using a computer now. Evaluate whether you should use a different code for these services now. Also check your documentation to ensure it supports the codes you’re using rather than virtual check-in or e-visit codes instead. The payers are watching, and you should be as well.
3. Conduct Quality Assurance Checks
What the toolkit suggests: Before payers can confirm whether telehealth services were billed accurately, they must first confirm that everything else on the claim is correct, which involves reviewing things like the provider’s NPI, the patient’s member ID number, the quantity of units billed and other factors.
How practices can react: Remember that the devil is in the details when it comes to telehealth claims. You can spend hours creating documentation to accurately convey what the provider did, but if you report the wrong date of service or NPI, your entire claim will be denied. Remember that payers are watching the minutiae, so you should do the same.
4. Analyze the Data to Identify Risks
What the toolkit suggests: Once payers have all of the data to review, they should analyze it to pinpoint where the practice is falling short. For instance, they may determine whether incident to claims performed over telehealth are compliant by analyzing just those specifically.
How practices can react: Gather your own data and perform your own analyses to identify your most pressing risk areas. Create spreadsheets for every category you analyze and classify the claim issues you find into different areas so you can determine how to address them.
5. Interpret the Results
What the toolkit suggests: After payers analyze the results of their reviews, they’re going to determine whether fraud occurred, if further analyses are needed, or whether they need to clarify billing rules across the board. Either way, payers are going to scrutinize their findings, and they’ll be reaching out to practices with next steps.
How practices can react: Perform your own interpretations and then create training materials to show your practice staff where you found telehealth issues, which areas fell short, and the next steps to improve upon the findings. It’s also a good idea to share what they’re doing correctly as well.
By proactively planning for payers’ reviews based on toolkit instructions, you’ll be able to head off compliance issues for your telehealth services.
Telehealth can be exceedingly complicated, and you need help to stay compliant. Fortunately, experts are here to pitch in. During her 60-minute online training, Stop 2023 Telehealth Billing & Coding Errors to Keep Cash Flowing, expert Kim Huey, MJ, CHC, CPC, CCS-P, PCS, CPCO will provide you with the strategies you need to keep your telehealth pay flowing.
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