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CMS Expands Telehealth Reimbursement During COVID-19 Pandemic

Posted by Michael Greiwe, MD on Apr 3, 2020 10:57:57 AM
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This week the Centers for Medicare & Medicaid (CMS) announced policy and guidelines changes to increase access to telemedicine services for Medicare beneficiaries. The COVID-19 public health emergency has prompted numerous organizations, including the U.S. Centers for Disease Control and Prevention (CDC) to recommend the use of telehealth as an effective way to provide healthcare while enforcing social distancing. The CMS announcement signals widening support for telehealth services for every practice in the nation. Here’s what the new policy waivers say and how it affects your practice.

CMS Rulings on Telehealth 1135 Waiver

According to the CMS Medicare Telemedicine Health Care Provider Fact Sheet, the goal of these new relaxed rules is so that, “beneficiaries can receive a wider range of services from their doctors without having to travel to a healthcare facility.”

This move was applauded by the American Hospital Association (AHA) as a way to ensure that patients, and particularly older patients at high risk of from the COVID-19 virus, have access to care without gathering in a crowded waiting room to wait for an appointment. However, the AHA did express concern that CMS fell short of providing licensure flexibility to allow clinicians to legally provide telemedicine in another state if they have equivalent licensure in their home state.

The CMS 1135 waiver fell under new legislation called the Coronavirus Preparedness and Response Supplemental Appropriations Action, which was signed by the President in March. The goal of CMS was to broaden access to telemedicine by making beneficiaries “aware of easy-to-use, accessible benefits that can help keep them healthy while helping to contain the community spread of this virus.”

Telemedicine, telehealth, and related terms, such as e-health or m-health, all refer to the exchange of medical information between a doctor and patient from one location to another by using digital technologies such as a desktop, laptop, tablet, or mobile device, and the Internet, to conduct a patient encounter.

Telemedicine has a several benefits over the traditional in-patient visit, generally, however, during a time of the global pandemic, these tools protect patients and clinical providers from unnecessary exposure to a deadly disease.

CMS Frequently Asked Questions About Telemedicine Reimbursement During COVID-19

  • What new CMS rules are in effect for telemedicine reimbursement?
    A new law passed on March 6 includes a provision allowing a waiver of specific telehealth payment restrictions during this time of public emergency. The specific goal was to allow CMS beneficiaries to receive telehealth care from their homes.

    Medicare beneficiaries can now receive care through telehealth, including common office visits, mental health counseling, and preventative health screenings from the privacy and safety of their homes. The waiver also stated:
  • Will my patients still have a copay for telehealth?
    Medicare coinsurance and deductibles will still apply. However, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) will have the flexibility to allow healthcare providers to waive or reduce the cost-sharing arrangements paid by federal healthcare programs.
  • How telehealth reimbursement different from the prior rules?
    Before the new ruling, clinicians could only be reimbursed for telemedicine is the beneficiary received services at an eligible originating site. Generally, the beneficiary’s home was not an originating site. This typically meant the patient still had to travel to a remote clinic or hospital to receive a video consultation. Under the new waiver, Medicare patients can receive care at home and doctors can be reimbursed.
  • Who can provide telehealth services?
    Any clinician authorized and credentialed to offer healthcare services, such as doctors, nurse practitioners, clinical psychologists, and clinical social workers, can offer care via telehealth services.
  • How much is reimbursement for telemedicine?
    Medicare has authorized payment parity for telehealth services. This means that a telemedicine visit is reimbursed at the same rate as an in-person visit. Coding should include the designated Place of Service (POS) code (02-Telehealth) to indicate the encounter was via a professional telehealth visit from a remote site.
  • Is the telehealth reimbursement only tied to COVID-19?
    No. The patient diagnosis doesn’t matter. This is an important point; the loosening of telehealth regulations is to encourage social distancing. The concern is that an elderly patient with chronic conditions may be exposed to the coronavirus when leaving their home. While telehealth is not meant to exclude or replace the in-person visit, many illnesses can be treated by phone or video conferencing.
  • What is the difference between virtual check-in vs. telehealth visits?
    Under the new waiver, a virtual check-in can occur from the patient’s home and is not required to initiate from an originating site.

While the existing patient requirement has been waived for telehealth, this is not true of the virtual visit HCPCS code G2012. The virtual visit is a brief communication between a patient and a qualified caregiver via virtual technology. The virtual visit is still only reimbursable with established patients.

  • Are there differences between types of telehealth visits?
    Yes, in addition to the standard telehealth visit and the virtual check-in there is a type of telemedicine called store and forward, or asynchronous telehealth. This technology allows doctors to upload and store data for later review. Asynchronous telehealth is covered by CMS under HCPCS code G2010. Some restrictions apply; for example, interpretation of the stored data and patient follow-up is required within 24-hours.

    Medicare also reimburses for e-visits, which occur within a patient portal. The established patient initiates these contacts over a secure website designed specifically for doctor-patient communications and patient education.
  • What about HIPAA?
    Many commercial videoconferencing services lack HIPAA compliance. However, under this recent ruling, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against healthcare providers that serve patients in good faith through everyday communications technologies.
  • How do I bill CMS for telemedicine services?
      • Medicare Telehealth Visits
        • 99201-99215 Office or outpatient visits.
        • G0425-G0427 Telehealth consultations, initial inpatient, ER
        • G0406-G0408 Follow-up inpatient telehealth consultations furnished to SNFs or hospitals.
    • Virtual Check-ins (established patients only)
        • HCPCS code 62012
        • HCPCS code G2010
    • E-Visits (online patient portals for established patients)
        • 99421-99423
        • G2061-G2063

From the American Hospital Association:


How To Implement Telehealth in Your Practice

SpringHealthLive offers small to mid-size practices an immediate way to implement telehealth in their practice. We can help implement telemedicine in your practice with an easy-to-use, customizable, and economical application that can have you up and running with a HIPAA-compliant telehealth visit quickly. Contact us today for how you can implement telehealth in your practice and keep your patients and providers safe.



Topics: About Telemedicine, "telehealth", "reimbursement", "telemedicine", doctor-patient relationship, CMS, telemedicine laws, Medicare Advantage, coronavirus, pandemic, infection, COVID-19