With the COVID-19 outbreak, medical professionals are increasingly relying on telehealth as a way to administer care while staying protected. Government agencies are rapidly adapting to this changing landscape with new policies and procedures. Casamba has created this Telehealth Resource page to help you keep you in the know.
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Can institutional providers (e.g., SNF, hospital outpatient department, rehab agency) provide and bill Medicare Part B for e-visits, virtual check-ins, remote evaluation of recorded video/images, or telephone assessments?
Yes, institutional providers may provide and bill these communication technology-based services on a UB-04. On May 26, 2020, CMS released Transmittal 10161 and an updated version of Medlearn Matters 11791 which add these services to the Therapy Code List for the duration of the public health emergency. In the MLN article, CMS references both private practice and institutional providers as being eligible to provide and bill these services with the appropriate GP, GO, or GN modifier indicating the service was provided as part of a therapy plan of care.
Can I provide e-visits or virtual check-ins to patients in a skilled stay in a SNF? What about a home health patient?
From a Medicare perspective, specific reimbursement for communication technology-based services, like e-visits and virtual check-ins, is via the Part B Physician Fee Schedule based on the number of units of specific HCPCS/CPT codes on the claim. Therapy services provided to patients in a Medicare Part A stay in a SNF or to a beneficiary in a home health episode paid under Medicare Part A are not separately billable to Medicare as a line item on the claim. All services provided to a SNF Med A resident or a patient under the care of a HH episode would be covered under the per diem or episodic rate received by the SNF or home health agency.
Are there particular requirements when it comes to the telehealth platform? Do they need to be HIPAA compliant?
For the duration of the national public health emergency (PHE) due to COVID-19, the HHS Office for Civil Rights (OCR) has waived penalties for HIPAA violations against health care providers “that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype.” Therefore, during the PHE, providers have some flexibility as to which method they use to communicate with patients in certain cases, although a HIPAA-compliant platform is always recommended. Check with your MAC and with each payer as to specific requirements regarding available technology.
Can PT/OT/STs provide telehealth under Medicare?
On April 30, 2020, CMS released a new blanket waiver that includes PTs, OTs, and SLPs as eligible providers of telehealth under Medicare Part B. At that time, only therapists in private practice (that is, those who bill on professional claims) were able to provide and bill for telehealth. On May 27, 2020, CMS clarified that therapists in institutional settings may bill also telehealth to Medicare Part B on a UB-04.
Can PTAs or OTAs conduct telehealth visits?
It depends on the state practice act and payer requirements. As for e-visits, those can only be conducted by a PT, OT or SLP.
Can PTAs or OTAs conduct e-visits, telephone assessments, or virtual check-ins?
No. These communication technology-based services may only be conducted by a PT, OT or SLP.
Are communication technology-based services (i.e., e-visits, virtual check-ins, and telephone assessments) considered telehealth?
No. These services are not considered telehealth. They do not equate to “treatment visits,” and are not replacements for clinic/in-person or telehealth visits. These services represent patient-initiated communications and are intended to address a patient-identified need that has arisen since the last interaction with the therapist and requires immediate attention.
Can more than one e-visit G-code be combined for billing?
No, only one G code can be billed to Medicare Part B for an e-visit based on cumulative time over a 7-day period. For more information on reimbursement, refer to the Medicare Physician Fee Schedule.
Is there a way for a SNF in a continuing care retirement community (CCRC) to use e-visits?
The “rules” for e-visits for Medicare Part B apply to all Medicare Part B beneficiaries, whether coming in to an OP clinic or residing in a CCRC. Note that the patient must initiate the e-visit and consent to it.
Can a clinician conduct a telehealth visit, e-visit, virtual check-in, or telephone assessment for an out-of-state patient?
The clinician must be licensed in (or have compact privileges in) the state where both the therapist and the patient are located.