March 2020 – Page 3

OIG issues a policy statement

OIG issues a policy statement and a factsheet regarding telehealth cost-sharing during the COVID-19 outbreak.

This is an important piece of the puzzle since the OIG needed to be on the same page with CMS on regulations to keep physicians out of hot water if they choose to waive patient portion for telemedicine.

A report and four enforcement actions are also posted. As always, you can use the links provided to go directly to the new material.

Policy Statement:

Waiving Telehealth Cost-Sharing During COVID-19 Outbreak https://go.usa.gov/xdtXC
Telehealth Factsheet https://go.usa.gov/xdtXT

From CMS MLN Connects

From CMS MLN Connects, two resources for telehealth see links below

Key take aways:

Question: Is any specialized equipment needed to furnish Medicare telehealth services under the new law?

Answer: Currently, CMS allows for use of telecommunications technology that have audio and video capabilities that are used for two-way, real-time interactive communication. For example, to the extent that many mobile computing devices have audio and video capabilities that may be used for two-way, real-time interactive communication they qualify as acceptable technology. The new waiver in Section 1135(b) of the Social Security Act explicitly allows the Secretary to authorize use of telephones that have audio and video capabilities for the furnishing of Medicare telehealth services during the COVID-19 PHE. In addition, effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency.

Q: How does a qualified provider bill for telehealth services?

A: Medicare telehealth services are generally billed as if the service had been furnished in-person. For Medicare telehealth services, the claim should reflect the designated Place of Service (POS) code 02-Telehealth, to indicate the billed service was furnished as a professional telehealth service from a distant site.

Q: How much does Medicare pay for telehealth services?

A: Medicare pays the same amount for telehealth services as it would if the service were furnished in person. For services that have different rates in the office versus the facility (the site of service payment differential), Medicare uses the facility payment rate when services are furnished via telehealth.

Q: Are there beneficiary out of pocket costs for telehealth services?

A: The use of telehealth does not change the out of pocket costs for beneficiaries with Original Medicare. Beneficiaries are generally liable for their deductible and coinsurance; 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.

https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet

https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf

Coronavirus (COVID-19): new telehealth rules and procedure codes for testing

From American Academy of Family Practice

Getting Paid – A Blog from FPM Journal

Tuesday
Mar 10, 2020

Coronavirus
(COVID-19): new telehealth rules and procedure codes for testing

Last
week, Congress passed the Coronavirus Preparedness and Response Supplemental AppropriationsAct.(www.congress.gov)
The legislation will allow physicians and other health care professionals to
bill Medicare fee-for-service for patient care delivered by telehealth during
the current coronavirus public health emergency.

In
particular, the legislation gives the U.S. Department of Health and Human
Services (HHS) secretary the authority to waive or modify certain telehealth
Medicare requirements when the President has declared a National Emergency, or
the HHS Secretary has declared a Public Health Emergency, as Sec. Alex Azar did in January(www.phe.gov).
For instance, the legislation gives the HHS secretary the authority to
waive the originating site requirement(www.cchpca.org) for
telehealth services provided by a qualified provider to Medicare beneficiaries(www.cms.gov) in
any identified emergency area during emergency periods. The legislation also
allows telehealth services to be provided to Medicare beneficiaries by phone,
but only if the phone allows for audio-video interaction between the qualified
provider and the beneficiary. This expansion is limited to qualified providers
who have furnished Medicare services to the individual in the three years prior
to the telehealth service (or another qualified provider under the same tax
identification number that has provided services within three years). The
patient must initiate the service and give consent to be treated virtually, and
the consent must be documented in the medical record before initiation of the
service.

As noted,
the waiver of the originating site requirement and expansion of telemedicine
modalities is limited to emergency areas identified by the President and HHS
Secretary during emergency periods. Accordingly, as a practical matter, this
expansion of payment is very limited. Further, health care providers must still
comply with state telehealth laws and regulations, including professional
licensure, scope of practice, standard of care, patient consent(www.cchpca.org),
as well as other payment requirements for non-Medicare beneficiaries.

The codes
that will be billed for what Medicare actually defines as Medicare “telehealth
services” will typically be evaluation and management (E/M) codes (for example,
99213, 99214) along with a telehealth Place of Service (POS) code(www.cchpca.org) and
potentially a modifier (if required by commercial payer). However, there are
additional services available for payment that are not ever restricted by
originating site and other Medicare telehealth regulations. The Medicare “communications-based technology” codes(www.cchpca.org) (e.g.
G2012) are not deemed by the Centers for Medicare & Medicaid Services (CMS)
to be Medicare “telehealth services,” which means they are not subject to the
statutory restrictions regarding originating site and rural geography. These
services can be furnished even when patient are in their homes, regardless of a
national emergency declaration. There are also time-based, online digital E/M
codes (99421, 99422, 99423) for established patients. Similar codes (G2061,
G2062, G2063) are available for online patient-initiated assessments provided
by qualified non-physician health care professionals.

Last week
CMS also announced that Medicare Part B would cover a test to determine if
beneficiaries have coronavirus for dates of service on or after Feb. 4, 2020.
But providers of the test will have to wait until after April 1, 2020, to
submit a claim to Medicare for the test. Most physician offices will not have
access to the test to perform it themselves, but may be ordering it for their
patients or collecting specimens (e.g. nasal swab or sputum) for testing. In
general, if the patient is in the office for an E/M service, the specimen
collection is bundled in that service. Otherwise, many contracts don’t include
specimen collection. You will need to check with the payers in your area on
this point.

CMS has
created two Healthcare Common Procedure Coding System (HCPCS) codes to report
testing for coronavirus. Labs that test patients for the new coronavirus using
the Centers for Disease Control and Prevention (CDC) 2019 Novel Coronavirus
Real Time RT-PCR Diagnostic Test Panel may bill for that test using the new
HCPCS code (U0001). This code is used specifically for CDC testing laboratories
to test patients for SARS-CoV-2. The second HCPCS billing code (U0002) allows
laboratories to bill for non-CDC laboratory tests for SARS-CoV-2/2019-nCoV
(COVID-19). On Feb. 29, 2020, the Food and Drug Administration (FDA) issued a
new, streamlined policy for certain laboratories to develop their own validated
COVID-19 tests. This second HCPCS code may be used for tests developed by these
additional laboratories when submitting claims to Medicare or health
insurers. Diagnosis coding for coronavirus is also
available.

What is
happening in the private health insurance sector remains unclear and may vary
from payer to payer. An industry trade group, America’s Health Insurance Plans, issued its own
statement last week(www.ahip.org). CMS also
issued a fact sheet on “Information Related to COVID–19 Individual
and Small Group Market Insurance Coverage.”(www.cms.gov)

For more
information, please see CMS’s frequently asked questions(www.cms.gov) for
health care providers regarding Medicare payment for laboratory tests and other
services related to the 2019 novel coronavirus. CMS has also provided related
fact sheets pertaining to Medicare(www.cms.gov) and Medicaid and the Children’s Health Insurance Program(www.cms.gov).

Coverage,
payment, and other aspects of getting paid for services related to the
coronavirus are continuously evolving. Stay tuned to the “Getting Paid” blog
for further updates. AAFP has more information about how to prepare for
COVID-19 here: https://www.aafp.org/patient-care/emergency/2019-coronavirus.html

— Kent
Moore, AAFP Senior Strategist for Physician Payment

Posted
at 04:30PM Mar 10, 2020 by Kent Moore

From the Patient Side of Medicare

E-visits

Medicare Part B (Medical Insurance) covers E-visits with your doctors and certain other practitioners. Be sure to check the above link for the latest changes!!!

Your costs in Original Medicare

You pay 20% of the Medicare-approved amount for your doctors’ services, and the Part B deductible applies.

What it is

E-visits allow you to talk to your doctor using an online patient portal without going to the doctor’s office.

Practitioners who may furnish these services include:

Doctors
Nurse practitioners
Physician assistants
Licensed clinical social workers, in specific circumstances
Clinical psychologists, in specific circumstances
Therapists, in specific circumstances

Note
E-visits can be used for the treatment of the Coronavirus (COVID-19) from anywhere.

NEW CPT® CODE ANNOUNCED TO REPORT NOVEL CORONAVIRUS TEST

The American Medical Association (AMA) announced that the CPT^® Editorial Panel approved a new addition to the Current Procedural Terminology (CPT^®) code set that will help streamline data-driven resource planning and allocation in the battle against the novel coronavirus (SARS-CoV-2) as the number of confirmed COVID-19 cases continues to rise.

For quick reference, the new Category I CPT code and descriptor are:

l 87635
Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique

The code is effective immediately for use as the industry standard for reporting of tests for the novel coronavirus across the nation’s health care system. In addition to the long descriptor, CPT code 87635 has short and medium descriptors that can be accessed on the AMA website.

Please note that, per the standard early release delivery process for CPT codes, you will need to manually upload this code descriptor into your EHR system. This CPT code will arrive as part of the complete CPT code set in the data file for 2021 later this year. To read the full press release click here.

New TMA Telemedicine Resources 3/16/2020

Texmed.org Article

As COVID-19 cases rise across the state, physicians have been asking the Texas Medical Association about getting started with telemedicine.

That’s why TMA staff has added new tools and information to the TMA telemedicine resource center, including:

Numerous policies, procedures, and forms;
A chart of payer policies that includes which Current Procedural Terminology (CPT) codes can be billed for telemedicine; and
A list of telemedicine vendors, including electronic health records (EHRs) vendors with integrated telemedicine products, and pricing when it was listed.

Additional resources on the telemedicine page include a white paper detailing Texas’ telemedicine
laws and regulations.
TMA will be working with health plans and the Texas Department of Insurance to clarify billing procedures and payment. Look for updates in Texas Medicine Today and the TMA telemedicine resource center.
We know these are uncertain times, but TMA is here to help. Do not hesitate to reach out to TMA’s Health Information Technology Department at (800) 880-5720 or via email.

Telephonic visit/consult from TMA

We asked the TMA if they could shed any light on the subject. This is their answer:

TMA is pushing from both directions, insurers and the Texas Dept of Insurance, to come up with a coherent payment scheme for telemedicine and telephonic visits.

We expect to meet with TDI this week and hope to make progress. So, far United Healthcare is the only insurance to release a statement:

https://www.uhcprovider.com/en/resource-library/news/provider-telehealth-policies.html

Visit TMA’s coronavirus resource page and TMA’s telemedicine resource page. I hope this information is helpful to you! Please don’t hesitate to contact me if I can be of further assistance!

Sincerely,

Claire Duncan
Director, TMA Knowledge Center
Texas Medical Association

TMB Responding to Gov. Abbott’s State Disaster Declaration

FOR IMMEDIATE RELEASE March 14, 2020

Media contact: Jarrett Schneider, 512-305-7018

Customer service: 512-305-7030 or 800-248-4062

Following Governor Greg Abbott’s state disaster declaration, the Texas Medical Board, with direction and assistance from the Governor’s Office, is implementing procedures to waive certain requirements to help the state’s physicians, physician assistants and other health care professionals respond to COVID-19.

Please check health plan links below for most current information – Telephone Consults/Visits Benefits?

This post was pinned to the top of all other new posts. I have now removed the pin. We are updating this as information comes in. Be sure to click the links for the most up to date information from the plan:

Aetna – Check below links for updates. ” Only telemedicine at this time. Self- funded plan sponsors can choose to not waive member cost share.”

Link for providers – https://www.aetna.com/health-care-professionals/provider-education-manuals/covid-faq.html

Link to members information from Aetna- https://www.aetna.com/individuals-families/member-rights-resources/covid19.html

BCBSTX – “This service is a benefit level and not all members have this benefit. Most employer plans are required to use MD Live.”

Check the below link for the most up to date from BCBSTX

https://www.bcbstx.com/provider/covid-19-preparedness.html

March 19th info from BCBS: New patients can be seen by telemedicine.

You will need to check eligibility and benefits as all groups will not have telehealth benefits.

CIGNA – has provided the following link: www.Cignaforhcp.com

They did not specify if Commercial only however it was from our commercial products contact.

CIGNA/HealthSpring – Letters are being sent to physicians regarding the situation. HealthSpring will be following CMS guidelines. Further details have been provided by HealthSpring. There was an update of the details on March 26th.

UPDATE – As of April 1, 2020 accepting 360s performed via telehealth(must be audio and visual). See April 2,2020 post for details.

March 31, 2020 find the latest by going to https://medicareproviders.cigna.com/ look for the blue box with a exclamation point and click on Billing Guidelines and FAQs

Molina – March 23 – Update and additional information can be found in COVID tag

March 19 – “We would expect that the visits would be covered based on the modifier and POS noted below:

Modifier 95* , POS 2* and document in their medical records that it was audio only *these are intended for visits with both video and audio,but we will also instruct providers to code for audio-only visits.”

Nexcaliber (Brookshires) – Will be working with Brookshire Brothers Employee Health Plan to allow reimbursement for robust telephone calls between physician and patient. This will be effective through April 30, 2020.

Superior – Will follow state regulations. Working to get better details.

The Governor’s release states:

“This coordinated efforts between the Office of the Governor, the Texas Department of Insurance, the Texas Medical Board, and health insurance plans will increase access to health care for all Texans. Today’s action will expand telemedicine options by giving health care providers greater flexibility to perform audio-only telephone consultations with their patients.

As a reminder, Texans covered by CHIP or Medicaid will not be charged copays for test or telemedicine consults. Individuals covered by Medicare or large employer plans should check with their health plan administrator to determine their specific benefits. “

United Healthcare – “You will find all information concerning COVID-19 for providers on the UHC Provider Service website.” The website describes how they will reimburse providers for telephone calls to existing patients based on type of product. https://www.uhcprovider.com/en/resource-library/news/Novel-Coronavirus-COVID-19.html

Considering Telemedicine in the Wake of COVID-19?

By Steve Levine,

texmed.org/TexasMedicineDetail.aspx

Much of America, Texas included, is engaged in a big “what if” conversation about what happens next with the coronavirus disease, COVID-19.

What if a lot of cases show up in my town?
What if schools must close?
What if I have to stay home for a week or longer?

The Texas Medical Association and organizations like the U.S. Centers for Disease Control and Prevention (CDC) and the World Health Organization are encouraging physicians to consider how they will respond to big surges in sick patients needing care; critical staff becoming ill or unable to come to work; and protecting non-infected patients from exposure to the virus from other patients in the office.

Could telemedicine be part of the solution for your practice?

“Shifting practices to triaging and assessing ill patients (including those affected by COVID-19 and patients with other conditions) remotely using nurse advice lines, provider ‘visits’ by telephone, text monitoring system, video conference, or other telehealth and telemedicine methods can reduce exposure of ill persons with staff and minimize surge on facilities,” CDC says in a recent guidance document. “Many clinics and medical offices already use these methods to triage and manage patients after hours and as part of usual practices.”

The laws and rules concerning telemedicine (members only white paper) in Texas have changed considerably to expand access over the past several years, in large part due to TMA’s efforts. In 2019 alone, the Texas Legislature passed a bill to streamline Medicaid’s telemedicine requirements, and another measure allowing physicians to choose the best platform for providing telemedicine services rather than having health plans dictate the platform.

For physicians looking to ramp up their telemedicine capabilities, TMA offers a 37-minute webinar, Telemedicine: The Changing Shape of Care, free to members thanks to the sponsorship of TMA Insurance Trust. TMA members are eligible for a free technology contract review from Coker Group, including a contract review of telemedicine vendor services, and TMA has created a free telemedicine vendor evaluation tool.

Texas Medicaid now can pay for services provided via telemedicine to patients who are in their homes under certain circumstances. Medicare Advantage plans can cover those services in patients’ homes for the first time this year; traditional Medicare cannot. Analysts tell TMA that, even in an emergency, the secretary of Health and Human Services (HHS) lacks the authority to waive the prohibition against paying for telemedicine services to patients who are in their homes; it requires an act of Congress. And this week, Congress acted.

The U.S. House of Representatives on Wednesday included authorization for HHS to take such actions in a declared national emergency as part of the coronavirus-response legislation that passed overwhelmingly. The Senate passed an $8.3 billion spending bill Thursday, and President Trump signed it Friday.

For up-to-date information on COVID-19, check TMA’s Coronavirus Resource Center. And turn to the TMA Telemedicine Resource Center for links, resources, and a look at TMA advocacy on telemedicine in Texas.

Last Updated On

March 09, 2020

Month: March 2020