Emergency Rule Changes: Due to the COVID19 Public Health Emergency (PHE), CMS is taking drastic steps to relax its rules in order to increase the ability for patients to be treated, and physicians to be paid, via TeleHealth services.
Rules are Changing Rapidly: Updates are being released constantly, by CMS and commercial payers, most likely as this is article is being written. As such, it is important to keep checking CMS and commercial payer websites on the latest guidance on this emerging subject.
TeleHealth Definition: While there are a few different types of virtual patient consults, the most important for the office-based image-guided procedure specialist will be Medicare TeleHealth Visits. As defined, Medicare patients may now use telecommunication technology for office visits and other services that otherwise would generally occur in person. A prior physician-patient relationship is not needed for claims submitted during this public health emergency, with limited exception.
Technology Required: The provider must use an interactive audio and video telecommunications system that permits real-time communication between the distant site and the patient at home. Mobile video includes applications such as Skype, FaceTime, Zoom, GoToMeeting, and others.
Coding and Payment: Medicare will reimburse the same amount for telehealth services as it would if furnished in person. Medicare will use the facility payment rather than the non-facility rate (office) when the service is furnished via telehealth.
New Patient Evaluation and Management Codes:
Established Patent Evaluation and Management Codes:
Place of Service: StreamlineMD has added POS 02 to its EHR to accommodate this change. Please contact your client rep if you have any questions on this function.
Patient Responsibility: Medicare coinsurance and deductibles will generally apply to these services, but HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.
HIPAA Compliance: Effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency.
For more information: Please see the CMS FAQ guide here and Medicare Telemedicine HealthCare Provider Fact Sheet here which were both released today. And, as stated above, please contact your local CMS and commercial payers for specific guidelines.