3 best practices you must implement to stay compliant and collect maximum reimbursement.
The flourishing of telehealth in 2020 was driven not just by necessity, but also by a significant loosening of governmental regulations and of reimbursement requirements by payers. Waivers were granted during the public health emergency that allowed the use of traditionally noncompliant communications platforms, such as FaceTime and other consumer-level technologies. Practices have been able to grab most any technology and expect to get paid for the appointment.
Today, both states and payers are already changing their rules and laws rapidly. A good first step for many practices is to wean themselves away from noncompliant communications to immediate implementation of a Health Insurance Portability and Accountability Act-compliant telehealth solution, which will be essential when the public health emergency is terminated.
To ensure that you will continue to be paid for your telehealth services, here are three best practices to be aware of:
Check to see if your state has proposed or passed legislation requiring insurance companies to cover telehealth.
Your local medical societies are often a good source of this information. Several states are already passing regulations regarding telehealth reimbursement requirements. Determine exactly what the regulations are in your state, whom they affect and when they go into effect.
Closely monitor bulletins and announcements regarding telehealth from any insurance payers that your practice accepts.
Payer policies are changing rapidly and unexpectedly. Do not assume that policies that applied in 2020 will continue. Make monitoring of payer policies at least a monthly discipline.
When you verify that a particular patient’s insurance accepts telehealth, determine if the coverage specifies the use of the payer’s approved telehealth vendor only. In that case, appointments conducted on the practice’s telehealth platform may not be covered. In some cases, state telehealth regulations might specify that the telehealth appointment must be allowed to be conducted with the patient’s regular provider, which could supersede the payer’s requirements. However, even if your state has such a requirement, be extra careful in 2021. There may be a gap between the implementation of state requirements and the provider contracts and policies that would postpone application of the state requirements until 2022.
What many providers and their staff may also not realize is that Employee Retirement Income Security Act rules override state laws regarding employer-based plans, so it is not safe to assume that a health plan covers telehealth services under the state-mandated guidelines. Always confirm the specific plan benefits for telehealth, and instruct billing staff to watch for payment discrepancies as the situation with the public health emergency evolves.
Update and clarify your practice’s financial policy regarding collection of copays for telehealth services.
To provide much-needed care during the pandemic, policies regarding collection of copays became very lax in many health care practices. Now is the time to remedy that. A clearly stated practice of collecting patient payments before service, just as would be done if the patient came into the office, should be in place, and practices should not hesitate to reschedule appointments if payments aren’t made. A procedure to maintain a credit card on file simplifies timely payments. Make sure patients receive a copy of your policies so that they know what and how much to expect to pay. When patients are unclear as to the amount owed, they tend to put off paying their health care bills.
There’s no doubt that telehealth is here to stay. Both practitioners and patients have discovered that telehealth is a viable approach to health care delivery. In fact, patients love the convenience of telehealth and now expect it as a delivery option. If a practice doesn’t offer telehealth, patients may go elsewhere. Therefore, it’s critical that independent practices stop considering telehealth a fortunate stopgap and make sure they are laying the groundwork to make telehealth a robust part of their care delivery — and their bottom line.