Telehealth medical billing: A look at recent changes to reimbursements for virtual care

Telehealth medical billing: An evolving landscape

Since the declaration of the national COVID-19 Public Health Emergency (PHE) in January 2020, the U.S. Health and Human Services (HHS) department has taken steps to make it easier for healthcare providers to offer telehealth services via two-way communication technology.

Telehealth — the all-encompassing term that includes patient consultation via videoconferencing, remote patient monitoring (RPM), medical education, wireless health applications, and the transmission of imaging and medical reports across a wide range of specialties — is a cost-effective means of expanding access to care.

As the pandemic continued, patients and providers alike enjoyed the benefits of telehealth as evidenced by its widespread adoption and use nationwide. In fact, virtual care is now standard at many practices and has become a mainstay in the provision of medical care.

Telehealth reimbursements: revisions to regulatory guidelines

But this widespread use of telehealth resulted from many months of trial and error, and numerous revisions to regulatory guidelines at federal and state levels to bring it into existence. Initially, the Centers for Medicare & Medicaid Services (CMS) implemented limits to the types of services that could be provided via telehealth and that would qualify for reimbursement.

Reserving the term telehealth only for those services that typically could have been provided in-person during pre-pandemic times, many telehealth-related claims were initially denied or reimbursed at lower rates.

Over time, however, CMS relaxed some of these rules, and now, more Medicare Fee-For-Service (FFS) services are billable as telehealth, although some are only reimbursable until the PHE ends.

With proper documentation, reimbursements are now made at parity rates, as if the services were provided in person. As the industry adjusted to making the practice of telehealth more permanent, medical coding modifiers are used to indicate the mode by which the services are provided, and associated claims are reimbursed accordingly.

New technological advancements supporting the use of communication technology-based services (CTBS) led to the creation of a separate category of codes for services only applicable for use in telehealth.

CMS has also expanded the list of covered Medicare services to include emergency visits, initial nursing facilities and discharge visits, home visits, and therapy services. These guidelines pertain to all providers who serve patients covered under Medicaid and Medicare, the Children’s Health Insurance Program (CHIP) as well as those providers offering services from Federally Qualified Health Centers (FQHC) and Rural Health Clinics (RHCs). FQHCs and RHCs have also started serving as distant telehealth sites, which has allowed Medicare patients to receive telehealth services at any site, regardless of type or location.

At the Federal level, the H.R. 366 - Protecting Access to Post-COVID-19 Telehealth Act of 2021 bill was introduced in the House on Jan. 19, 2021, to accommodate for this mode of providing medical services. This bill proposes that FQHCs and RHCs permanently serve as distant sites for providing telehealth services and that payments be made in the same manner as for non-telehealth services. While this proposed legislation was referred to the Subcommittee on Health in February 2021 — and as of a year later has yet to become federal law — many states have proceeded to adjust their legislation and have provided regulatory guidance to address their individual needs.

The Center for Connected Health Policy (CCHP), in its Fall 2021 publication titled State Telehealth Laws and Medicaid program policies  indicated that some states made changes to their pandemic policies and extended some temporary ones for multiple years. In some cases, the changes have been made permanent.

In states where the PHE policies and local laws have been adjusted, the list of allowable CMS codes has gotten longer. Now GT modifiers and Point of Service (POS) codes, along with CTBS codes, are being used in routine telehealth billing as providers continue to provide these services. 

Telehealth: The case for integrated EHR and practice management

Nearly two years after the first declaration of the COVID-19 PHE, telehealth use has contributed to a dramatic increase in patient satisfaction, especially among those in rural areas where provider shortages had affected care delivery. This is attributable to the improvement in access to care, as well as the reduction in stress resulting from the shorter wait times and eliminated travel times.

Medical providers have also become more efficient in the provision of care services, resulting in higher quality of care. Similarly, independent providers and medical facilities alike are reporting reduction in costs, despite the initial  hindrances in the adoption of telehealth services due to regulatory and legal barriers to telehealth reimbursements.

Medicaid and Medicare plans continue to be updated at the state level across the country, but in general telehealth services are now at least partially covered by most health insurance plans, including private ones.

Since the beginning, transitioning to telehealth services provided a potential means of reducing healthcare spending by decreasing hospitalization stays, unnecessary emergency room visits, and medication misuse. Thus, the full-scale implementation of telehealth services has positive implications for the U.S. healthcare system in general for the long term. But these advances also have some associated downsides due to still-unresolved issues.

For patients, the lack of familiarity with the use of technology among older adults, as well as sub-par internet bandwidth speeds in certain rural areas, can create obstacles. Another real concern is not being able to ensure patients are in locations that will preserve their confidentiality while they are being attended to. So is the potential for digital security breaches that may occur with the use of unencrypted home internet services.

In general, the legal and regulatory implications include variations in rules, standards, and guidelines that differ from state to state.

Charting a path forward

What began as a way to adjust to a pandemic has developed into a standard method of providing medical care. Practices and independent providers may benefit from innovative technology solutions that integrate with their EHR and practice management system, so as to ensure all telehealth services are provided in compliance with regulatory guidelines and billed accurately.

Telehealth encounters are vulnerable to privacy and security risks, and this highlights the importance of a provider’s choice in telehealth services. Greenway Telehealth™ provides a secure method for providers to ensure continuity of care with patients. It improves workflow efficiency while facilitating telehealth medical billing using an integrated, HIPAA-compliant platform that supports interoperability.