Coding changes regarding telehealth and transitional care management physicians need to know during the pandemic.
Q: With the move to Telemedicine to help address Coronavirus and keep patients safe at home what are the restrictions on my use of this technology? And how does this impact payment?
A: Things are changing quickly and you need to pay close attention to not only CMS communications but those of your state’s Medicare contractor, payer communications and local government agencies.
The Telemedicine Toolkits released by CMS on 3/17/20 and 3/23/20 spell out the core requirements for Telemedicine/Telehealth and also direct you to a list of covered Telehealth services.
The general idea here is that the geographic limitations of the patient’s location have been lifted, temporarily, and HIPAA restrictions related to synchronous audio/video have been lifted as well. This opens the door to the use of common apps such as Facetime, Google Hangout, Skype and Messenger video chat.
Several providers have indicated that their older patients are not familiar with these modalities and can really only deal with a phone call. CMS has not allowed a phone call between provider and patient to be billed as Telehealth using the office visit or other Telehealth eligible codes.
The G2012 brief communication technology-based virtual check-in code does cover the telephone per the 2019 Final Rule, but it doesn’t pay anything like the office visit codes.
But as above this could change quickly. On Friday The State of New Jersey waived the video portion and also any site of service requirements – for the patient and the provider. The State has waived any site of service requirements to allow licensed clinicians to provide telehealth from any location and individuals to receive services via telehealth at any location. This means the provider doesn’t need to be in the office either. CMS has already indicated that with POS service 2 – home – they will be paying office codes at the facility rate – not the office rate – thus removing the overhead payment component.
Some providers had already suggested that they would do what needs to be done for the patient, which includes coping with their technological limitations, and will just call them.
Pay close attention to your State Health agencies and local CMS contractors for updates here.
Q: Can we do the ‘face-to-face’ portion of the Transitional Care Management codes using Telemedicine remotely as well?
A: Yes. The TCM codes 99495 and 99496 are also on the CMS list of Telemedicine services. There are a lot of components of that overall service that can already be done remotely: communication with family members or caretakers and home health agencies, the review of discharge information, reviewing diagnostics, helping with referrals and follow up with other health care entities. But now the included visit itself, within the specified time frames, can also be done ‘remotely’ given the more open and remember, temporary’, coverage of Telehealth during this health care crisis.
Remember that these services are intended to reflect your oversight of the patient’s ‘transition’ back into the community – it’s not just about the hospitalization. The expectation is that the A/P or decision-making will not only address the issues principally responsible for the hospitalization – but any core chronic conditions the patient has. Don’t forget to make sure that management is visible as well.