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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

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.

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

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.

Read More

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

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

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Coronavirus

Steve Levine

VP, Communication

(512) 370-1380

steve.levine[at]texmed[dot]org

A former statehouse reporter, political press secretary, and state agency spokesman, Steve Levine has directed the Communication Division at TMA since 1997. He oversees Texas Medicine, Texas Medicine Today, TMA’s media and public relations activities, and the TMA Knowledge Center, website, and social media activities.

This is the question of the week! POET is working on getting some sort of definite answer. We are posting web links and information provided by health plans when asked the question.

So far it appears most are easing policies on telemedicine (audio and visual) but no changes for telephone. We are in hopes there will be reconsiderations as events unfold.

We will keep you posted on what we learn. If anyone gets a definitive answer in writing, we would love to see it!

Effective immediately, UnitedHealthcare is expanding their policies around telehealth services for our Medicare Advantage, Medicaid and commercial membership, making it even easier for patients to connect with their health care provider

To view UHC policies follow this link.

For UHC Provider’s Resource Library on CoVID-19, Corona Virus https://www.uhcprovider.com/en/resource-library/news/Novel-Coronavirus-COVID-19.html

ICD-10-CM Official Coding Guidelines – Supplement Coding encounters related to COVID-19 Coronavirus Outbreak Effective: February 20, 2020

For the official document follow this link.