The document discusses proper billing and reimbursement for telemedicine. It provides information on HIPAA compliance for video conferencing solutions and recent changes to HIPAA policies during COVID-19. The document outlines billing codes for telehealth visits, telephone evaluations, place of service codes, and telehealth options for various specialties. It also reviews benefits of telemedicine such as increased access to healthcare, improved outcomes, and lower costs.
3. Teleheath vs. Video
Conferencing
Is video conferencing HIPAA compliant?
Not a complex question, but the question can seemingly bring on
several types of answers. The simple answer is that video
conferencing can be compliant with the government’s mandate
for health security standards. However, not all major video
conferencing solutions can meet the Health Insurance Portability
and Accountability Act of 1996 (HIPAA) standard, especially not big
industry names like Skype and Facetime.
In order for a health organization to ensure they are in good
accordance with the HIPAA regulation, they will need to err on the
safe side so it’s recommended that any provider using a video
conferencing solution, must have a solution that offers complete
encryption of any personal patient data. As telemedicine
continues to grow and become a norm in today’s society, more and
more video conferencing solutions are increasing their security
standards to meet the standards of HIPAA and other security
protocols.
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4. HIPAA Policy Changes
during COVID-1
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The current pandemic has dramatically increased the need for Telehealth.
-While HIPAA rules have been relaxed, violations may still be levied. It is very important
that we remain compliant as much as possible.
-The provider must use an interactive, real-time audio and video telecommunication
system in order to bill office visit codes 99201–99215. If the patient does not have access to a
smart phone or computer, do not bill office visit code
- CMS specified that Facebook Live, Twitch, TikTok or other public facing video tools should
NOT be used for telehealth.
-HIPAA privacy rules waived: may use FaceTime, Skype, Messenger video chat, Google
hang-outs video.
-CMS instructs groups to notify the patient that third party platforms may have privacy
risk
-The provider may waive the co-pay / deductible but is not required to do so.
-Visits are paid at the same rate as in person visits.
-You do NOT need to record visits on any platform.
-You DO need to document the visit in the EMR
-You need to write a proper note using the telehealth
template including a history, limited physical exam and
an assessment/plan.
5. Tools & Tips
for
Documentation
Accurate documentation is just as important for
telehealth visits.
Pre-COVID only established patients were
allowed for telehealth, during COVID New
patients are also allowed
The accepted codes are only the e/m codes.
However during COVID Well visits are also
included. Good practice is to inform the patient
prior to call the requirements
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You MUST DOCUMENT time in your note by clicking the time
button in your EMR or using the time quick text. Protocols
will remain same as a face-to-face visit, must have at least 2
out of 3 – HISTORY / PHYSICAL / MDM to determine e/m
coding level
Good practice to document the ‘originating’ and
‘distant’ sites, indicating the location of provider
and the patient
6. Telephone Evaluation and
Management Services (CPT
99441-99443)
On March 30, 2020, CMS finalized payment for telephone evaluation
and management (E/M) services (CPT 99441-99443). Effective March 1,
2020, the codes will be considered active and payable for the
duration of the COVID-19 pandemic. CMS will allow physicians to
provide telephone E/M services to new and established patients.
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● Telephone E/M services are provided to a patient, parent, or guardian and do not
originate from a related E/M service within the previous seven days and do not lead to
an E/M service or procedure within the next 24 hours or soonest available
appointment.
● The following codes may be used by physicians or other qualified health professionals
who may report E/M services:
○ o 99441: telephone E/M service; 5-10 minutes of medical discussion
○ o 99442: telephone E/M service; 11-20 minutes of medical discussion
○ o 99443: telephone E/M service, 21-30 minutes of medical discussion.
● Physicians can reduce or waive cost-sharing for these services.
● Reimbursement is lower than the audio-video encounter.
● Commercial will require patient benefits verification
● Medicare (+MA) also accepts G2012 for virtual check-in and this has been in place prior
to COVID. It is only applicable for 5-10 minutes interaction and can be conducted
through multiple communication technology modalities, including synchronous
telephone conversation or exchange of information through video or image. Call must
only be initiated by the patient.
● Corresponding E-Visit codes are separate and corresponding NP/PA codes are
separate
7. Place of Service
In 2017, CMS developed
Place of Service (POS) code
(02) for telemedicine
services.
- On 3/30/2020, CMS said
you are not required to use
POS 02, but should use the
place of service that would
have been used if the
patient was seen face-to-
face. This means, the office
visit services will be paid at
the higher, non-facility rate,
not the lower, facility rate.
8. Telehealth for Specialties
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Clinicians who may not independently bill Medicare for E/M services
(i.e., physical therapists, occupational therapists, speech language
pathologists, clinical psychologists) can use the following codes.
● G2061: Qualified non-physician health care professional online
assessment and management, for a patient, for up to 7 days,
cumulative time during the 7 days, 5-10 minutes
● G2062: Qualified non-physician health care professional online
assessment and management, for a patient, for up to 7 days,
cumulative time during the 7 days, 11-20 minutes
● G2063: Qualified non-physician health care professional online
assessment and management, for a patient, for up to 7 days,
cumulative time during the 7 days, 21 or more minutes
● Commercials although have more extensive code coverage –
including IE/RE / Therapeutic Activities, etc. However patient
benefits must be checked.
Invited Guest
9. Follow-up visits
any limitation on follow-up
visits in terms of number of
days between the two
sessions
-Currently there is no
limitation in number of days
between the two sessions of
telemedicine encounters.
- However, there are
limitations for e-visits,
where the patient must
generate the initial inquiry
and asynchronous
communications can occur
over a 7-day period.
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10. INCREASES ACCESS TO HEALTHCARE
REMOTE PATIENTS DON'T HAVE TO TRAVEL FOR
TREATMENT. INSTEAD, THE DOCTOR WILL COME TO
THEM IN A VIRTUAL VISIT.
RURAL/METROPOLITAN HOSPITALS CAN HAVE VIDEO
CONSULTS WITH SPECIALTY PROVIDERS.
CHRONICALLY ILL PATIENTS CAN HAVE DAILY
MONITORING IN THE COMFORT OF THEIR OWN HOMES.
IMPROVE HEALTHCARE OUTCOMES
INCREASE THE MONITORING OF CHRONIC CONDITIONS
BENEFITS OF TELEMEDICINE
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11. REDUCE NO-SHOWS. PATIENTS WILL BE LESS LIKELY TO
SKIP FOLLOW-UP OR ROUTINE PREVENTATIVE
TREATMENT WHEN THEY DON'T HAVE TO TRAVEL FOR
CARE.
IMPROVE MORTALITY, REDUCE COMPLICATIONS, CUT
HOSPITAL STAYS, AND READMISSIONS.
LOWER HEALTHCARE COSTS
REDUCE READMISSIONS, ER VISITS, AND PATIENT
TRANSFERS
REDUCE MEDICAL PRACTICE OVERHEAD
BENEFITS OF TELEMEDICINE
Last Slide
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12. Presented by:
Wayne Roye, CEO
Guest speaker:
Rohit Maharishi, CEO
QUESTIONS
wroye@troinet.com
718-761-2780
www.troinet.com