The healthcare industry and the patients it serves continues to navigate how to best cope with, and begin to move forward from, the challenges caused by the COVID-19 pandemic. Clinicians are working tirelessly to provide high-quality care to their patients and now, more than ever, there is a need for simple, secure, and reliable technology to connect patients to their care teams.
The Centers for Medicare and Medicaid Services (CMS), State Medicaid programs, and many major insurance payers including Blue Cross Blue Shield and United Healthcare have relaxed their existing guidelines for telehealth services, making it easier for providers to be reimbursed for their services and patients to gain access to care.
As of March 6, 2020, CMS specifically began paying physicians and other qualified non-provider professionals (QPPs) for all telehealth visits, including 80 additional codes during this public health emergency. No longer is Medicare requiring their patients to be in an HPSA (federally defined rural area) or be in an approved originating site such as another doctor’s office, federally qualified health center, hospital, etc. Patients may now receive these telehealth visits while at home and their providers can get paid just as they would if the patient was in the office. CMS has also said they will no longer be auditing to ensure that the patient was an “established patient” with the billing provider, which allows clinicians to render and bill for medical services for new patients as well.
Typically, all telehealth services are subject to CMS’ standard co-insurance and deductible amounts, leaving most Medicare patients with a balance due. As a rule, the reduction or elimination of these amounts owed by Medicare beneficiaries potentially violate the Federal Anti-Kickback Statute, the civil monetary penalty rule, and exclusion laws. In response to the COVID-19 pandemic, the Health and Human Services (HHS) Office of Inspector General (OIG) issued guidance to ensure physicians and other qualified non-provider professionals are not subject to these sanctions for reduced or eliminated beneficiary cost share amounts for telehealth or e-visits.
In addition, CMS has now recognized several new virtual check-in codes that they have categorized as communication-based technology services (CBTS). These CBTS codes include both remote evaluation of pre-recorded patient information (CPT code G2010) and virtual check-ins (CPT code G2012), each with an average allowable amount between $12 – $15.
CMS has published two valuable resources including their General Medicine Telehealth and Telemedicine Toolkit and their Medicare Learning Network (MLN) Booklet on Telehealth Services which detail their new guidance on telehealth services and billing requirements in response to the COVID-19 health crisis. In addition, on April 23, 2020, the Trump Administration released a new COVID-19 State Medicaid & CHIP Telehealth Toolkit designed to further expand the widespread provider adoption and patient usage of telehealth services as the preferred means of delivering and receiving high-quality and effective health care.