Q: What are the different types of telemedicine services?

https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet

Physicians may also reduce or waive cost-sharing for telehealth visits. 

Q: What are the time requirements for Physicians billing telehealth and E-visit codes?

Q: Which place of service (POS) code should I use?

POS Code: 02 Telehealth

***Update - Providers have been instructed to use the original POS code the visit would have taken place in during the COVID-19 national emergency. ie. if this visit would have taken place in the provider's office, use POS Code: 11. ***

https://www.cms.gov/Medicare/Coding/place-of-service-codes/Place_of_Service_Code_Set

Q: What is informed consent and is it required for reimbursement?

“The process of informed consent occurs when communication between a patient and physician results in the patient’s authorization or agreement to undergo a specific medical intervention.”

https://www.ama-assn.org/delivering-care/ethics/informed-consent

The requirement to document informed consent has been temporarily waived as a result of the COVID-19 pandemic, however, practitioners should maintain adequate documentation wherever possible in addition to notifying patients of privacy risks and maintaining adequate safeguards over information.

https://www.aafp.org/news/health-of-the-public/20200323covidtelehealth.html

See our help article here for additional resources.

Q: What are the documentation requirements for telehealth encounters?

According to Steven Waldren, M.D., vice president and chief medical informatics officer for the AAFP, “‘documentation requirements for any form of virtual care ("telehealth service" or non-telehealth digital online service) are the same as those for documenting in-person care.

If a code is time-based, evidence of time must be documented,’ he said. ‘If exchanged asynchronously, videos, images and communications must be stored, for billing purposes, and retained for a duration pursuant to state regulation. Real-time (synchronous) videos, such as during a video visit, or video phone call (temporarily permissible for billing purposes) are not required to be stored.’”

https://www.aafp.org/news/health-of-the-public/20200323covidtelehealth.html

Q: Do commercial insurers and Medicare advantage plans reimbursement guidelines match those of CMS?

Medicare Advantage plans must follow rules set by traditional Medicare. Some Medicare advantage plans also have additional policy options that go above and beyond traditional Medicare Part B . Additionally, commercial insurance provides a vast array of benefits with some covering telehealth visits and others excluding these services. 

Several commercial payors such as UHC and BCBS have offered to remove “originating site” restrictions from all Medicare, Medicaid and commercial policies during the COVID-19 pandemic. We recommend you reach out to each beneficiary’s insurance company to verify which benefits are covered with regards to telemedicine.

***Additional commercial insurance guidelines for telehealth:

Humana - https://www.humana.com/coronavirus/covid19-humana-member-resources

Cigna-  https://static.cigna.com/assets/chcp/resourceLibrary/medicalResourcesList/medicalDoingBusinessWithCigna/medicalDbwcCOVID-19.html

Aetna - https://www.aetna.com/health-care-professionals/provider-education-manuals/covid-faq.html#acc_link_content_section_responsivegrid_copy__responsivegrid_accordion_11

UHC - https://www.uhcprovider.com/en/resource-library/news/Novel-Coronavirus-COVID-19/covid19-telehealth-services.html

BCBS - https://www.bcbs.com/press-releases/media-statement-blue-cross-and-blue-shield-companies-announce-coverage-of-telehealth-services-for-members***

Q: Do patients need to be established in order to bill for telehealth services?

CMS will not enforce a requirement that patients have an established relationship with the physician providing telehealth.

https://www.ama-assn.org/delivering-care/public-health/cms-payment-policies-regulatory-flexibilities-during-covid-19

Q: Is there an end date for the reimbursement of telehealth services?

Effective March 6 and throughout the national public health emergency, Medicare will pay physicians for telehealth services at the same rate as in-person visits for all diagnoses, not just services related to COVID-19. Commercial insurance reimbursement timelines may vary.

https://www.ama-assn.org/delivering-care/public-health/cms-payment-policies-regulatory-flexibilities-during-covid-19

Q: Do I still need to comply with HIPAA?

CMS has waived some requirements related to informed consent and has indicated the OCR will waive potential HIPAA penalties for good faith use of telehealth during the emergency. This does not waive a provider's responsibility to comply with HIPAA in other instances and all providers are still strongly encouraged to follow all HIPAA guidelines wherever possible. “In an emergency situation, covered entities must continue to implement reasonable safeguards to protect patient information against intentional or unintentional impermissible uses and disclosures. Further, covered entities (and their business associates) must apply the administrative, physical, and technical safeguards of the HIPAA Security Rule to electronic protected health information.”

https://www.hhs.gov/sites/default/files/hipaa-and-covid-19-limited-hipaa-waiver-bulletin-508.pdf

https://www.hhs.gov/about/news/2020/03/17/secretary-azar-announces-historic-expansion-of-telehealth-access-to-combat-covid-19.html

Q: Do I need to be licensed in the state of the patient I am providing care for?

Physicians licensed in one state can provide services to Medicare beneficiaries in another state. State licensure laws still apply.

https://www.ama-assn.org/delivering-care/public-health/cms-payment-policies-regulatory-flexibilities-during-covid-19

Q: Do the previous geographic and rural site requirements still stand?

All geographic and rural site requirements have been temporarily waived. “Patients can receive telehealth services in all areas of the country and in all settings, including at their home.”

https://www.ama-assn.org/delivering-care/public-health/cms-payment-policies-regulatory-flexibilities-during-covid-19

https://www.uhcprovider.com/en/resource-library/news/Novel-Coronavirus-COVID-19/covid19-telehealth-services.html

Q: Are Behavioral Health, Physical Therapy, Occupational Therapy, Speech Therapy covered under new guidelines?

Several commercial insurance companies have updated their guidelines to allow for reimbursement of these telemedicine services. UHC has included a sample list of CPT codes for these services here. Check with your patient’s insurance carrier before treatment in order to verify benefits and coverage.

Additional CMS telehealth codes can be found here

Please let us know if you have other questions you’d like answers to and remember the most important factor is delivering care to those in need.

The team at Doxy.me is here to make sure the interruption to your practice is minimal and you and your patients 💙 telemedicine.

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