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Documentation and Billing for Telemedicine Visits during COVID-19

telemed
05 Apr

Documentation and Billing for Telemedicine Visits during COVID-19

Documentation and Billing for Telemedicine Visits during COVID-19

The urgency of expanding technology use has prompted a greater need for support for patients requiring routine care. Moreover, we want to keep vulnerable patients or those with mild symptoms at home while maintaining access to necessary care. Consequently, CMS broadened access to Medicare Telemedicine services under President Trump’s guidance.

Under the new 1135 waiver, effective March 1, 2020, Medicare patients can receive certain services at home. These services include Telemedicine and other virtual options, such as evaluation and management visits, mental health counseling, and preventive health screenings. Importantly, this waiver will remain valid throughout the COVID-19 Public Health Emergency.

We developed the frequently asked questions presentation below to assist our customers proactively during these challenging times.

Effective Use of Telemedicine in Your Medical Practice

1. Which providers are eligible for Telemedicine services?

Please see the list below of providers who can furnish and get reimbursed for covered Telemedicine services at this time:

  • Physicians
  • Nurse Providers
  • Physician Assistants
  • Nurse Midwives
  • Certified Nurse Anesthetists
  • Clinical Psychologists
  • Clinical Social Workers
  • Registered Dietitians
  • Nurse Professionals

2. How will the Telemedicine services be paid?

Telemedicine services will be considered the same as in-person visits and paid at the same rate as regular in-person visits.

3. What technologies are available to provide Telemedicine services?

Regarding technology, providers must use an interactive audio and video telecommunications system that permits real-time communication between the provider and the patient at home. Considering ease of use and HIPAA compliance, some recommended platforms (in no particular order) include:

www.doxy.me

www.connectoncall.com

www.vsee.com

www.simplevisit.com

www.mendfamily.com

www.evisit.com

Furthermore, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion. They will waive penalties for HIPAA violations against healthcare providers serving patients in good faith. This waiver applies to everyday communications technologies, such as FaceTime or Skype, during the COVID-19 public health emergency.

However, it is essential to note that Facebook Live, Twitch, TikTok, and similar public-facing video apps should not be used for virtual care (Source: www.hhs.gov).

4. What are the critical methods of providing virtual services, including documentation and billing options?

Below are three main types of virtual services that providers can provide to their patients:

Service

Applicable Codes

Modifier

POS1

Medium

Patient Visit Documentation2
Telemedicine Visit 99201 – 99205, 99211 – 99215
For a complete list of codes, click here.		 95 for Medicare;
GT or other for non-Medicare (check payer rules)		 11 • Audio/Video
  • Schedule patients as usual.
  • At the visit time, your MA and patient log into the Telemedicine platform.
  • Document in EHR that the service was via Telemedicine.
  • Note the patient’s location (e.g., at home).
  • Document like an in-office visit.
  • For 99201–99215, no need for history or exam levels for service selection.
  • Bill by Total Time or override level based on MDM.
  • If billing by time, record the total time spent and its distribution. Billable time is for providers, not staff.
  • Document a detailed assessment based on disease complexity.
  • Unlike Virtual Check-ins, recordings aren’t required; use office visit notes.
  • If the patient cannot access a smartphone or computer, do not bill 99201–99215; consider Virtual Check-in or Phone Visit instead.
Virtual Check-in Visit G2010
G2012 (5-10 minute discussion via phone)		 Check payer rules 11 • Audio
• Image
  • Applicable to new and established patients who initiate communication.
  • The patient must verbally consent.
  • Not related to a visit in the past seven days and does not lead to a medical visit in the next 24 hours.
  • Record time spent and save any images to the patient’s chart.
Phone Visit 99441 – 99443 (Physician)
98966 – 98968 (NP, PA, etc.)		 11 • Audio
  • 99441 – 99443 applies to new and established patients who initiate communication.
  • 98966 – 98968 applies to established patients.
  • Patient must verbally consent.
  • Not related to a visit in the past seven days and does not lead to a medical visit in the next 24 hours.
  • Record time spent.
E-Visits Via Patient Portal 99421 – 99423 (E&M Providers)
G2061 – G2063 (Non-E&M Providers)		 Check payer rules 11 • Portal
  • 99421 – 99423 applies to new and established patients.
  • G2061 – G2063 applies to established patients.
  • Verbal consent is required.
  • Communication occurs through the patient portal.
  • Communications can occur over seven days.
  • Record time spent.

*Notes:

5. Are there any additional documentation requirements for a Telemedicine visit?

Firstly, it is best to document the time for virtual visits that use time-based coding. Importantly, you are not required to store the call data for telemedicine visits, including synchronous real-time and interactive video-phone calls. Similarly, for a phone visit, you don’t need to save the call data; you only need to document the visit and time spent. However, you must store asynchronous images, videos, and related data for a Virtual Check-in visit.

6. Does the provider need to obtain consent from the patient for a virtual visit?

While you do not need to obtain informed consent from a patient before the service, Medicare recommends notifying the patient that using a third-party Telemedicine platform for virtual service may involve potential security and privacy risks.

7. Are new patient visits included in Telemedicine services?

For Medicare Telemedicine services, the patient must have an established relationship within the past three years but can also be a new patient. To clarify, the 1135 waiver does require an established relationship, but HHS will not conduct audits to ensure such a prior relationship existed for claims submitted during this public health emergency. For more information on establishing patient-provider relationships specific to your state, please refer to a website here.

8. Can ancillary staff bill for virtual services, e.g., MAs, Nurses, and other non-physician staff?

Only two categories of staff can bill for Telemedicine services. For Telemedicine and Virtual Check-in visits, the provider must be able to bill for an E/M visit. A nurse, MA, or technician performing these services cannot bill. The service is not billable when the physician does not communicate directly with the patient.

For E-Visits, codes ranging from 99421-99423 can be used if the services were provided by an E/M provider, e.g., Physician, NP, PA, etc. In contrast, non-E/M providers, e.g., Physical Therapists, can use codes ranging from G2061-G2063.

9. Can the practitioner provide Telemedicine services from a location other than their office, e.g., the practitioner’s home?

Yes, a practitioner can provide services from a location other than the practitioner’s practice, such as the practitioner’s home. In this scenario, such an address must be listed on the claim.

CMS no longer requires providers to enroll their home address (or other alternate address) with their MAC. It will disregard discrepancies between a provider’s enrolled address and the address where services were provided during the COVID-19 emergency.

10. Can a practitioner provide telemedicine services outside of their state?

Per waiver 1135, a provider does not need to be licensed in the state where the patient is located to render Telemedicine services. Nevertheless, we recommend you refer to your state-specific guidelines by clicking here.

11. Do Medicare coinsurance and deductibles apply to virtual visits?

For Medicare, it is optional for providers to lower or waive copays. Regarding non-Medicare payers, it is recommended that you check specifically with the respective payers in your jurisdiction.

12. Are there any specific requirements for Telemedicine visit documentation for Federally Qualified Health Centers (FQHCs) and Rural Health Centers (RHCs)?

For FQHCs or RHCs, the geographic and site restrictions still apply. In other words, FQHCs and RHCs can be the originating sites for Telemedicine services. However, the patient must be at the site, not home.

Furthermore, evaluation or discussion must be unrelated to a visit in the past seven days and cannot lead to a medical visit in the next 24 hours. Finally, FQHCs and RHCs must use HCPCS code “G0071” with the modifier “GT.”

13. How can providers e-prescribe controlled substances during a COVID-19 emergency?

For e-prescribing controlled substances, DEA-registered providers can issue prescriptions during the COVID-19 emergency without in-person evaluations. Providers must meet the following conditions for patients to receive controlled substance prescriptions remotely:

  1. Firstly, the prescription must be issued for a legitimate medical purpose by a provider acting in the usual course of his/her professional practice.
  2. Secondly, Telemedicine communication must be conducted using an audio-visual, real-time, two-way interactive communication system.
  3. Finally, the provider must act according to applicable federal and state laws.

14. How does the Accelerated/Advance Payment Program help providers with cash flow?

To increase cash flow to providers impacted by the COVID-19 emergency, CMS has established an Accelerated/Advance Payment Program. Under this program, providers can request advanced payments to help cover costs for 120 days after receiving the advanced payment. Amounts advanced under this program will be recouped from the provider’s Medicare billings commencing at the end of such 120-day period. Details on the eligibility and the request process are outlined here.

15. Is the COVID-19 emergency going to impact MIPS reporting in 2020?

On March 22, 2020, CMS announced relief for clinicians, providers, hospitals, and facilities participating in quality reporting programs in response to COVID-19. First, they have extended the deadline for attestation for the 2019 MIPS report to April 30, 2020.

In addition, MIPS-eligible clinicians who attest to two or more performance categories (Quality, Improvement Activities, and Promoting Interoperability) by April 30, 2020, as an individual or group, will score on those categories and receive a 2021 MIPS payment adjustment based on their 2019 MIPS final score.

However, CMS will reweight the MIPS performance categories for MIPS-eligible clinicians who do not submit their 2019 MIPS data by the extended deadline of April 30, 2020. As a result, these MIPS-eligible clinicians will have all four performance categories weighted at 0 percent and receive an MIPS final score equal to the performance threshold, resulting in a neutral adjustment for the 2021 MIPS payment year.

Sources:

CMS Frequently Asked Questions:  https://www.cms.gov/files/document/medicare-Telemedicine-frequently-asked-questions-faqs-31720.pdf

CMS Fact Sheet on Telemedicine:  https://www.cms.gov/newsroom/fact-sheets/medicare-Telemedicine-health-care-provider-fact-sheet

Disclaimer:

This information serves as a tool to help you understand recent changes in telemedicine billing due to COVID-19. Notably, TriumpHealth employees and staff have created this presentation to the best of their knowledge and ability. However, they make no representation or guarantee that it is entirely error-free. Therefore, TriumpHealth holds no liability to any person or entity regarding revenue loss or indirect damages from this information’s use.

by Tej Gill, VP – Healthcare Solutions | TriumpHealth