There will never be a time where face-to-face visits will be obsolete, but COVID-19 has changed our world and brought a heightened awareness and acceptance of telemedicine. If your practice or organization has not mobilized virtual visits, I recommend you get on board quickly. Now is the time to evaluate and reset your practice or organization and find ways to expand your services via telemedicine.
Every life has been impacted by the COVID-19 pandemic, and all our lives have changed, but we cannot let this crisis define us. We need to define the “new normal” and what that will look like for healthcare patients and providers. We have learned a new way to connect through video services to our families, our friends, AND our patients. We can connect and interact with our teams and, most importantly, obtain our healthcare services. We have learned that our patients do not have to be in close proximity or mobile. Although telemedicine has been around for years, our healthcare system recently experienced a rapid launch of virtual visits. This has brought about some changes that may likely be permanent, from the newly recognized “qualified independent healthcare providers,” to the utilization and expansion of patients that we are able to reach, to the reimbursement policies enacted and enforced by Medicare and the federal government in response to the public health emergency (PHE).
Medicare greatly expanded access to telehealth (real-time, interactive audio/visual) services. Patients across the entire country can now receive telehealth services in all settings, including their homes. Practitioners can provide telehealth services from their homes to new and established patients. Medicare has expanded its list of covered telehealth services and now allows a large volume of these services to be performed by telephone. These audio-only services have been expanded to include behavioral health, patient education, and counseling services. Payment for these services has been increased from the range of $14-$41 to a range of $46-$110, which is comparable to reimbursements for office/outpatient visits. This change is effective as of April 30, 2020, but retroactive from March 1, 2020, by Medicare.
In addition, the COVID-19 PHE regulatory waivers have provided significant relaxation in the guidelines including:
- Licensure: CMS waived the Medicare requirement that a physician or non-physician practitioner must be licensed in the State in which s/he is practicing.
- Limitations on Practitioner Type: For the duration of the COVID-19 PHE, CMS waived provider billing restrictions for telehealth services.
- Frequency Limitations: CMS waived limitations on the number of times certain services that can be provided via telehealth, including subsequent inpatient visits, subsequent skilled nursing facility visits, and critical care consults.
- Home Health Services: Nurse practitioners, clinical nurse specialists, and physician assistants may now provide home health services.
- Outpatient Maintenance Therapy: CMS will allow physical and occupational therapists to delegate maintenance therapy services to physical and occupational therapy assistants working in outpatient settings.
- Diagnostic Tests: CMS is adding flexibility for providers (NPs, clinical nurse specialties, PAs, certified nurse midwives) that can furnish services directly and incident to their own services, within their state scope of practice.
Major commercial payers are initiating coverage policy changes similar to Medicare, including expanding the list of telehealth services and recognized providers, waiving originating site requirements, and waiving member cost-sharing. Check with your carriers for coverage details.
In another unprecedented action, Medicare temporarily waived the requirement for documentation of history and/or examination for an E/M service. A practitioner may use MDM or time to select the code, with time defined as “all of the time associated with the E/M on the day of the encounter.”
- Office/Outpatient E/M Services (99201–99215) provided via telehealth- history or physical exam not required for the level of service selection.
- Provide total time spent ONLY by the practitioner (not staff) during the visit, whether counseling dominates the visit or not, -OR-
- Use MDM as currently defined
Practitioners should continue to be focused on appropriate documentation, coding, and billing of these services. Compliance is still in effect!
Practitioners and patients have embraced our new virtual normal. While there is likely to be some decrease in the relaxation of the guidelines and payment increases, many of these changes are projected to remain in place after the PHE.
Change is only difficult if we focus on the negative, and our challenging experience is not purposeless if we can produce positive change. Telemedicine is a positive and growing medical treatment option that is here to stay! Let’s reshape our vision and embrace the virtual future of healthcare.
Pam D’Apuzzo, CPC, ACS-EM, ACS-MS, CPMA