COVID-19 Support: How to Bill for Expanded Telehealth Services

© 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com
Presented by
Megan Smith
HRG Exec Director, Training & Quality
COVID-19 Support: How to Bill for
Expanded Telehealth Services

Telemedicine
Healthcare and education provided remotely using
telecommunications technology
Virtual Check-ins
Brief technology communication for established patients.
Must be unrelated to medical visit within previous 7 days
and/or does not lead to a medical visit in next 24 hours
Store-and-Forward
Two-way communication in which recorded information
from patient is sent to the provider for review and follow up
Originating Sites
Location of an eligible Medicare beneficiary at the time the
service is furnished via a telecommunication
Distant Site Practitioners
Practitioners at the distant site who may furnish and receive
payment for covered telehealth services
KEY INDUSTRY TERMS

Originating Site Geographic Restrictions
Waived
• Service dates beginning March 6, 2020, CMS has waived the
originating site geographical restriction
• This means the patient can receive telehealth services from
their home using a smart phone, computer or tablet
• Expansion includes all diagnosis codes – which means the
patient can use telehealth from home regardless if they’re
experiencing COVID-19 symptoms or for unrelated medical
concerns
Facilities cannot bill originating site fee (Q3014) if patient is calling
from location outside of a qualified originating site
WHAT’S CHANGED

Additional Services Added to Fee Schedule
• CMS announced 85 additional services on 3/28/2020 with formal notification included
in MLN Connects Special Edition March 31, 2020
• Codes date back to 3/1/2020 and are published on CMS website
• Additional services include Emergency department E&Ms (not subject to EMTALA
during PHE), Home visit (est./new), Hospital discharge, Initial OBS care, Nursing facility,
Critical Care (adult/peds) PT, OT and Speech therapy
• New services should be billed using place of service (POS) equal to what it would have
been in the absence of a PHE
• CMS advised modifier 95 must be appended to indicate services provided via
telehealth
CMS COVID-19 TELEHEALTH CHANGES

Patient Prior Relationship Requirement Waived
• Providers are encouraged to use telehealth technologies during time
of public health emergency
• Both new and established patients can utilize telehealth for diagnosis
and treatment of COVID-19, as well as conditions unrelated to the
pandemic
• HHS will not conduct audits on claims submitted during public health
emergency

Providers Can Use Additional
Technology
• The Office of Civil Rights announced they will waive
potential HIPAA penalties for good faith use of non-
public facing applications that allow for video chat
• Includes Apple Face Time, Skype, Microsoft Teams,
WebEx and GoToMeetings
• Excludes Facebook Live, Twitch, TikTok and other
public facing applications
• MLN Connects 3/31/2020 advised providers can now
evaluate beneficiaries who have audio phones only

Flexibility to Reduce or Waive Patient Cost
Share
• CMS Advised the out of pocket cost share for
beneficiaries stays the same; however the OIG has
given the option for providers and insurance payers
to reduce or waive fees during this time.

March 10th CMS Memo Provides Flexibility to Managed Plans
• Medicare Advantage Organizations can expand telehealth services beyond what’s
currently approved by CMS during this time
• Previous referral requirements may be waived
• Plans can choose to waive prior authorization requirements that otherwise would
apply to tests or services related to COVID-19 as well as Part D drugs used to
prevent or treat COVID-19
• Provide patients seeking care in a non-contracted facility the same level of
coverage as a contracted provider
CMS GUIDANCE TO MEDICARE MANAGED PLANS

March 10th CMS Memo Provides Flexibility to Managed Plans
• Allow changes that benefit the enrollee immediately without the 30-day
notification requirement (such as waiving referral requirements)
• Relaxing the “refill too-soon edit” for Part D sponsors
• Relaxing in network pharmacy requirements to provide same level of coverage for
out of network pharmacies
• Part D sponsors permitted to voluntarily relax plan-imposed policies discouraging
certain methods of delivery, such as mail or home delivery, for retail pharmacies
that choose to offer these delivery services in these instances
CMS GUIDANCE TO MEDICARE MANAGED PLANS

• As of March 31, 2020; 40 states have applied for and been approved for
waivers under Section 1135 of the Social Security Act
• Waiver provides relief in many areas such as prior authorizations, provider
enrollment requirements, suspends certain nursing home pre-admission
reviews and more
• For state specific Medicaid information, visit: https://www.cchpca.org
WHAT IS MEDICAID DOING?

INSURANCE
NAME
WAIVING
ORIGINATING
SITE?
COST SHARE
REDUCTION?
EARLY MEDICATION
REFILL?
WAIVING PRIOR
AUTHORIZATION
REQUIREMENTS?
Aetna
Including Medicaid,
Medicare & Self Funded
plans
Yes
Yes
Self funded can
opt out
Yes Not Specifically Noted
Blue Cross & Blue
Shield
Yes Yes Yes COVID19 tests only
Cigna Yes Yes Yes COVID19 tests only
Regence
Including Medicaid &
Medicare plans
Yes Yes Yes COVID19 tests only
United Healthcare
Including Medicaid &
Medicare plans
Yes Yes
Not Specifically
Noted
COVID19 Testing
Site of Service Surgical
Codes Thru April 30th
WHAT ABOUT COMMERCIAL INSURANCE?

CMS Issued Long-Term Care Nursing
Homes a Telehealth and Telemedicine
Tool Kit
Most of the items included in the kit are relevant for all
telemedicine providers and worth looking in to
• Details regarding expanded telehealth services
• Links for state statute guidance, an implementation
guide and other supporting documents/resources
• Telehealth vendor selection guidance and checklists
• COVID-19 articles and patient/community resources
• Resource:
https://www.cms.gov/files/document/covid-19-
nursing-home-telehealth-toolkit.pdf
TELEHEALTH TOOL KIT

• Physicians
• Nurse practitioners (NPs)
• Physician assistants (PAs)
• Nurse-midwives
• Clinical Social Workers (CSWs)
• Clinical Nurse Specialists (CNSs)
• Certified Registered Nurse Anesthetists
• Clinical psychologists (CPs)
• Registered Dietitians
• Nutritional Professionals
CMS Accredited Distant Site List Remains The Same
• CMS has waived requirements for CRNA supervision
• Licensed health care workers can support hospital efforts with relaxed credentialing
requirements
• Teaching physicians can provide resident supervision using audio/video
communication
• CMS permitting wider use of verbal orders rather than written orders
IMPACT TO PROVIDERS

Method I CAH
• Appropriate CPT or HCPC code
• Billed on 1500 claim form
• Place of Service (POS) 02
• Do not include the GT modifier
Method II CAH
• Appropriate CPT or HCPC code
• Billed on UB04 claim form
• Type of Bill (TOB) 851
• Revenue code 096x, 097x or 098X
• GT Modifier appended to E/M line
BILLING MEDICARE FOR DISTANT SITE

March 2020, AMA provided direction on billing drive thru COVID19 Assessment,
Specimen Collection and Testing
Based on location of drive thru, if independent testing site, 99001 can be reported for
swab collection
• Specimen collection billed on 1500, with place of service 15: Mobile Unit
• Append CR modifier to indicate catastrophe related. CMS announced the use of CR modifier
for COVID19 on March 20, 2020 MLN #SE20011
• CMS system ready to accept claims with CR modifier 4/1/2020. This includes claims with
services dates prior to April
BONUS SLIDE: COVID-19 DRIVE THRU TESTING

Center for Connected Health Policy; National Telehealth Policy Resource Center
https://www.cchpca.org/resources/covid-19-telehealth-coverage-policies
CMS FAQ, dated March 17th, 2020
https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf
CMS Memo to Medicare Advantage Organizations, dated March 10, 2020
https://www.cms.gov/files/document/hpms-memo-covid-information-plans.pdf
OCR Guidance on HIPAA
https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-
discretion-telehealth/index.html
State Specific Telehealth Payer Guidance
https://www.cchpca.org/telehealth-policy/current-state-laws-and-reimbursement-policies
AMA Guidance for Drive Thru COVID19 Specimen Collection:
https://www.ama-assn.org/system/files/2020-03/cpt-reporting-covid-19-testing.pdf
CMS MLN Matters #SE20011
https://www.cms.gov/files/document/se20011.pdf
ADDITIONAL COVID-19 TELEHEALTH RESOURCES

COVID-19 Support: How to Bill for Expanded Telehealth Services

Recommended

Recommended

More Related Content

What's hot

What's hot (20)

Similar to COVID-19 Support: How to Bill for Expanded Telehealth Services

Similar to COVID-19 Support: How to Bill for Expanded Telehealth Services (20)

More from Healthcare Resource Group Inc.

More from Healthcare Resource Group Inc. (20)

Recently uploaded

Recently uploaded (20)

COVID-19 Support: How to Bill for Expanded Telehealth Services