Telehealth has become essential to providing care during the COVID-19 pandemic. Through virtual care, practices can remain productive while maintaining social distancing requirements, in addition to extending access to new patient populations.
Given its continued adoption, telehealth is likely to remain in place after the crisis subsides. Meanwhile, payer rules and reimbursements was cited as the top operational challenge related to telehealth, a June 4 MGMA Stat poll found.
How can you ensure your practice receives telehealth reimbursement when you’re still learning to navigate the changing guidelines? Start with these three tips for telehealth billing.
Understand telehealth services types
Different types of services and interactions fall under the telehealth billing umbrella. The Centers for Medicare & Medicaid Services (CMS) has outlined three types of virtual care services — the classic telehealth visit, virtual check-ins, and e-visits.
Telehealth visits: These visits involve an interactive audio and video telecommunications system that connects the provider and patient in real time.
Virtual check-in: This refers to a brief communication with a provider, lasting about five to 10 minutes, that a number of technologies may facilitate. It could be a phone call or the exchange of a video or digital image to determine whether an office visit or other service is needed.
E-visit: This non-face-to-face communication between provider and patient occurs via an online patient portal.
It’s important to understand these differences because the type of visit will influence coding, as well as which patients can be seen, who can provide telehealth services, and how they can provide these services.
Research information from different payers
As you gather information from payers, remember each will have its own standards and terminology. In this dynamic environment, payers have issued frequent changes and that trend is likely to continue.
Payers share updates in a variety of ways. A few examples include:
Medicare may provide updates through local coverage determinations (LCDs), national coverage determinations (NCDs), and, more recently, the Medicare Learning Network (MLN).
Humana has medical policies.
Anthem Blue Cross and Blue Shield may publish theirs under a utilization management (UM) guideline.
As you search for payer updates, keep in mind these may vary by state, payer, and even line of business. Ensure any changes are offered across lines of business in your area.
Another ever-present question concerns how long payers will reimburse for telehealth. On July 23, Department of Health and Human Services (HHS) Secretary Alex Azar announced an extension of the COVID-19 public health emergency (PHE) by at least 90 days, thus extending changes to telehealth reimbursement.
Following the announcement, many payers updated their policies accordingly. Timelines differ between payers, and for this reason, it’s important to stay updated.
CMS has declared its intention to expand telehealth services permanently for Medicare patients, particularly those who live in rural areas. With its proposed changes, CMS reinforced the view that telehealth is an effective solution that complements in-person care.
Tips to consider for coding a telehealth visit
As your practice applies telehealth billing codes, be sure to identify the right code in the right setting — a code for a telehealth consultation in the emergency department versus a follow-up in an inpatient setting, for example.
Different payers require different Place of Service (POS) designations for telehealth. As an example, at the beginning of the PHE, Medicare used POS code 02 for telehealth. It has since requested the POS code 11 with the 95 modifier for certain visits. Be sure to check with payers as their telehealth requirements for billing, including codes and modifiers, may vary and continue to change.
Additionally, it’s important to consider whether you need to obtain consent. While it’s not required in every state, you should check your state guidelines and obtain consent prior to beginning the telehealth visit, where needed.
There are many other considerations for billing for the different telehealth visit types, such as HCPCS/CPT codes, appropriate modifiers, who can render the service, whether it’s synchronous or asynchronous (live videoconferencing vs. transmission of recorded health history, for example) and whether a patient can be new or must be established to be seen.