CMS has announced the expansion of Medicare coverage and payment for telehealth and telemedicine visits. This coverage and payments were granted under the President’s emergency declaration and this expanded benefit is on a temporary and emergency basis under the 1135 waiver authority and the Coronavirus Preparedness and Response Supplemental Appropriations Act starting March 6, 2020. This was an expansion of what was already being reimbursed on a limited basis in rural areas.
The telehealth payments cover three types of telemedicine visits: Medicare Telehealth Visits, Virtual Check-ins, and E-Visits. Here are the key takeaways from all 3:
Medicare Telehealth Visits
- Effective for services starting March 6, 2020 and for the duration of the COVID-19 Public Health Emergency, Medicare will make payment for Medicare telehealth services furnished to patients in broader circumstances.
- These visits are considered the same as in-person visits and are paid at the same rate as regular, in-person visits.
- Starting March 6, 2020 and for the duration of the COVID-19 Public Health Emergency, Medicare will make payment for professional services furnished to beneficiaries in all areas of the country in all settings.
- While they must generally travel to or be located in certain types of originating sites such as a physician’s office, skilled nursing facility or hospital for the visit, effective for services starting March 6, 2020 and for the duration of the COVID-19 Public Health Emergency, Medicare will make payment for Medicare telehealth services furnished to beneficiaries in any healthcare facility and in their home.
- The Medicare coinsurance and deductible would generally apply to these services. However, the 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.
- To the extent the 1135 waiver requires an established relationship, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency.
The big news here is that it can be at any location and that they’ll be paying for the visit at the regular in-person visit rate. Not conducting audits on the prior relationship is a bid deal as well that I’ve heard will be important for many that are treating patients in unique situations.
- Virtual check-in services can only be reported when the billing practice has an established relationship with the patient.
- This is not limited to only rural settings or certain locations.
- Individual services need to be agreed to by the patient; however, practitioners may educate beneficiaries on the availability of the service prior to patient agreement.
- HCPCS code G2012: Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.
- HCPCS code G2010: Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment.
- Virtual check-ins can be conducted with a broader range of communication methods, unlike Medicare telehealth visits, which require audio and visual capabilities for real-time communication.
This check in will be good for those working to track patients they’ve seen in person and want to check in with regularly around coronavirus concerns. However, it will also provide reimbursement for existing patients who you might normally see in office for a follow up visit, but which you can now visit remotely even without a full video visit. How this plays out now will be important for the future of remote patient monitoring reimbursement.
- These services can only be reported when the billing practice has an established relationship with the patient.
- This is not limited to only rural settings. There are no geographic or location restrictions for these visits.
- Patients communicate with their doctors without going to the doctor’s office by using online patient portals.
- Individual services need to be initiated by the patient; however, practitioners may educate beneficiaries on the availability of the service prior to patient initiation.
- The services may be billed using CPT codes 99421-99423 and HCPCS codes G2061-G206, as applicable.
- The Medicare coinsurance and deductible would generally apply to these services.
These visits are interesting since it talks specifically about an e-Visit on a patient portal. It feels like this one needs more specificity of what’s required to be performed in the portal. It also says that the communication can occur over a 7-day period. I’m not that familiar with these codes, but I’m guessing that those details are specified with those codes.
Worth noting, OCR will waive penalties for HIPAA violations against healthcare providers that use everyday communications technologies. These new options will open up even more opportunities for patients to be served and clinicians to get paid for that work.
Lots to process in the above and new processes to consider to make sure that healthcare organizations get reimbursed for these services. However, finding more ways to pay for telemedicine efforts is a great thing given the current situation. I’m interested to see if other healthcare payers will follow Medicare’s lead in this regard.
Also, here’s the short summary of the Medicare Telemedicine reimbursement changes:
UPDATE: Christina Farr shared that all 36 Blue Cross Blue Shield plans are expanding coverage for telehealth services.
NEW: All 36 BCBS plans and the Blue Cross and Blue Shield Federal Employee Program are expanding coverage for telehealth services, which includes waiving cost-sharing for all telehealth services for fully-insured members.
— Christina Farr (@chrissyfarr) March 19, 2020