Master 4 FAQs, Increase Your Telehealth Reimbursement

With telemedicine rules changing daily, you’ve got to have a solid foundation in telehealth guidelines, so you can make the most of adding these services compliantly to boost your pay during the COVID-19 pandemic.

To help healthcare practices treat more patients virtually, Congress passed legislation that allowed the U.S. Department of Health and Human Services (HHS) secretary to waive or modify telehealth Medicare requirements during a National Emergency. Navigate the changes by refreshing your terminology understanding.

While the terms Telemedicine and Telehealth are often used interchangeably, they have distinct differences. Telehealth is defined by CMS as remote clinical services—such as diagnosis, assessment, consultation, and treatment—which are usually provided real‐time, by a licensed physician or health professional acting under physician supervision. Telemedicine is a little bit broader by that—it’s pretty much all healthcare interactions that are not in person.

Telemedicine consists of the use of electronic information and telecommunications technologies to support long‐distance clinical health care, patient and professional health‐related education, and public health and health administration. Telemedicine can include nonclinical services, provider training, remote patient monitoring, administrative meetings and matters, continuing education, and quality improvement activities. Many of the principles that apply to telehealth as the subset of telemedicine also apply to telemedicine more broadly.

What Is the Originating Site?

The originating site is where the beneficiary (patient) is physically located during the visit. There are a number of locations that qualify as Telehealth Originating Sites. Specifically, originating sites authorized by CMS include:

A patient’s home (new in 2020 Telemedicine Policy Changes)
Physician or practitioner office
Hospital or Critical Access Hospital (CAH)
Rural Health Clinic
Federally qualified health center (FQHC)
Hospital-based or CAH-based renal dialysis center (including satellite locations)
Skilled Nursing Facility (SNF) or Community Mental Health Centers (CMHC)
Renal Dialysis Facility and the homes of beneficiaries with End-Stage Renal Disease (ESRD) on home dialysis
Mobile Stroke Unit

Note: A patient’s workplace and an independent renal dialysis facility are not acceptable Telehealth Originating Sites. Make sure you know specifically what you’re state’s requirements and limitations are regarding Telehealth Originating Site.

Emergency changes: Under the public health emergency declaration, HHS waived the originating site requirement for telehealth services provided by a qualified provider to Medicare beneficiaries. according to waiver 1135, Medicare can pay for office, hospital, and other visits furnished via telehealth across the country and including in patient’s places of residence starting March 1, 2020.

How Do E‐prescribing, Online Prescribing, and Internet Prescribing Differ?

E‐prescribing is electronically sending a prescription to a pharmacy, generally through an EHR. In an effort to curb opioid use, some states have mandates for e-prescribing. Online prescribing is prescribing based solely on an online patient interaction. You have to establish all elements of your provider‐patient relationship before you do online prescribing.

Alert: This is a big trouble area. In some states when the provider patient relationship is based solely on an online interaction, online prescribing is prohibited. The concern is that it allows for improper, “pill-mill” prescribing and raises the question to whether the patient has sufficient information to decide upon treatment, which is an informed consent issue. Internet prescribing permits prescribing pursuant to a Telemedicine relationship if certain conditions are met.

Internet prescribing is authorized by Ryan Haight Online Pharmacy Consumer Protection Act, which placed the prescribing of controlled substances via telemedicine under jurisdiction of the Drug Enforcement Agency (DEA). States maintain much control over Internet prescribing, with differing requirements which change often. Some states allow physicians to prescribe without a physical examination, some require a face-to-face exam, and some require an established physician-relationship. It’s important to know your state law regarding Internet prescribing.

Are Skype and FaceTime Approved for Telehealth Conferencing?

Normally, Skype and Apple FaceTime are not secure so they aren’t HIPAA‐compliant. Under the Emergency Notice issued March 19, HHS permits their use.

Emergency changes: Under this Notice, covered health care providers may use popular applications that allow for video chats, including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype, to provide telehealth. During the COVID-19 public health emergency, OCR will not impose a penalty for noncompliance with the HIPAA Rules related to the good faith provision of telehealth.

Tip: Notify patients that these third-party applications potentially introduce privacy risks. Enable all available encryption and privacy modes when using such applications.

The legislation also allows telehealth services to be provided to Medicare beneficiaries by phone, provided the call includes audio-video interaction between the qualified provider and the beneficiary. To qualify, the provider must have furnished Medicare services to the individual in past three years prior to the telehealth service. The standard documentation requirements apply including that the patient must initiate the service and give consent to be treated virtually, and the consent must be documented in the medical record before initiation of the service.

For Medicare telehealth services, you should bill an evaluation and management (E/M) codes (such as 99213, 99214) along with the intended usual Place of Service (POS) code such as a service that would have usually occurred in the office (POS 11). Under the public health emergency waiver, CMS has said to reserve telehealth Place of Service (POS) code 02 for facility charges; using it will decrease payment by 15%.

Capture More Remote Services with Virtual Care Coding

You can also get paid for remote services using virtual care codes which are never restricted by originating site and other Medicare telehealth regulations. CMS does not count the communications-based technology codes (e.g. G2012) as telehealth services. Therefore, the originating site and rural geography statutory restrictions do not apply. These services can be furnished even when patient are in their homes, regardless of a national emergency declaration. For established patients, you can also use online digital E/M codes (99421, 99422, 99423) and (G2061, G2062, G2063).

Emergency changes: There is so much more to know about Telehealth/telemedicine. Both the technology and government regulation and oversight of telehealth/telemedicine is rapidly evolving. The only way to help your staff and your practice by using the applicable codes is to have a firm handle on the requirements.