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The Complete Guide to Telehealth During COVID-19 in One Webinar

APRIL 9, 2020

WEBINARS BY AZCOMP TECHNOLOGIESEMPOWERING SMALL PRACTICES TO DELIVER THE BEST CARE

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The Complete Guide to Telehealth During COVID-19What will this webinar include?

➢ Telehealth Waiver Due to COVID-19

➢ Telehealth Options Including Live Demonstration

➢ Documentation Tips

➢ Telehealth billing guidelines during the COVID-19 National Emergency

➢ Collecting from Patients Remotely

➢ Citing the Most Up to Date Information fromAuthoritative Resources

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DisclaimerPlease note that his information was current as of April 9, 2020 at 11am, however newguidance is being delivered daily, please check cited resources frequently for updates!

Although AZCOMP Technologies makes every effort to ensure that information regarding billing guidelines are checked and accurate in both our documentation and training, it should be understood that our expertise is in the software itself and not in billing practices. Therefore, it is the sole responsibility of the user to study, interpret and remain abreast of billing requirements and deadlines, contacting authoritative sources directly as needed. Any claims documentation and training provided by AZCOMP Technologies is based on our interpretation of the rules published by nucc.org and cms.gov and are subject to change. Information and training provided is “as is” and without any express or implied warranties. AZCOMP Technologies assumes no responsibility for any inaccuracies, errors, or omissions, expressly disclaiming liability for damages of any kind arising out of the use of, reference to or reliance on any content provided.

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Expansion of Telehealth with 1135 Waiver

PRESENTER: LOREE OLSEN

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Payer InformationInformation provided in this webinar is specific to Medicare

For Medicaid check: https://www.medicaid.gov/resources-for-states/disaster-response-toolkit/coronavirus-disease-2019-covid-19/index.html

For Private Insurers check: https://www.ahip.org/health-insurance-providers-respond-to-coronavirus-covid-19/

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Current EventsMarch 6, 2020 – Congress passed the Coronavirus Preparedness and Response Supplemental AppropriationsAct (www.congress.gov). This new 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.

March 17, 2020 – The Trump Administration announced further expansion of Telehealth coverage for Medicare beneficiaries during the COVID-19 outbreak.

March 17, 2020 – After meeting with the Trump Administration many insurance issuers announced that they are also expanding efforts by waiving copays, waiving prior authorizations, covering the cost of the COVID-19 test, and allowing reimbursement for telehealth. (For details see Health Insurance Providers Respond to COVID-19)

March 18, 2020 – CDC Announces new ICD-10-CM code for COVID-19 will be effective April 1, 2020

March 18, 2020 The Families First Coronavirus Response Act becomes law, which among other things includes health provisions that require private health insurance to cover testing for COVID-19 without cost-sharing (deductibles, co-payments or co-insurance), and requires Medicare to cover, without cost-sharing, visits to health care providers that relate to COVID-19 testing during the public emergency.

March 30, 2020 CMS Announces Additional Waivers and New Rules to Address COVID-19 Patient Surge

March 31, 2020 CMS released an interim final rule, “Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency.” This rule further expands telehealth including additional covered services and new/modified billing instructions during the COVID-19 pandemic.

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Significant changes in the past few days!Since the Interim Rule became law “Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency.” a lot has changed so double check anything you saw published before April 1, 2020!

Revisit what you knew before as there have been significant changes!

• Expansion of telehealth may give you more options in the way you provide telehealth and what you can bill for.

• Billing changes may require you to correct and resubmit claims for previous telehealth visits in order to get a higher reimbursement.

Highly Recommend Reading CMS Letter sent 4/7/2020: Dear Clinician

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Types of Virtual Services

• Telehealth Visits

• Virtual Check-Ins

• eVisits

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Definition of Telehealth

The provider must use an interactive audio and video telecommunications system that permits

real-time communication between the distant site and the patient at home.

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

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What Services Can Be Provided• Evaluation and Management Visits (Common Office Visits)

• Mental Health Counseling

• Preventative Health Screenings

• NEW More than 80 Additional Services Added (see Interim Rule)

https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheetCovered Telehealth Services: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes

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What can you use?…Providers may use popular applications that allow for video chats, including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, Zoom, or Skype, to provide telehealth without risk that OCR might seek to impose a penalty for noncompliance with the HIPAA Rules related to the good faith provision of telehealth during the COVID-19 nationwide public health emergency. Providers are encouraged to notify patients that these third-party applications potentially introduce privacy risks, and providers should enable all available encryption and privacy modes when using such applications.

Under this Notice, however, Facebook Live, Twitch, TikTok, and similar video communication applications are public facing, and should not be used in the provision of telehealth by covered health care providers.

https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html

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HIPAA COMPLIANT VENDORS ENCOURAGEDCovered health care providers that seek additional privacy protections for telehealth while using video communication products should provide such services through technology vendors that are HIPAA compliant and will enter into HIPAA business associate agreements.

https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html

• Skype for Business/Microsoft Teams• Updox• VSee• Zoom for Healthcare• Doxy.me• Google G Suite Hangouts Meet

• Cisco Webex Meetings/Webex Teams• Amazon Chime• GoToMeeting• Spruce Health Care Messenger

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Who can Provide Telehealth Services• Physicians

• Nurse practitioners

• Physician assistants

• Nurse midwives

• Certified nurse anesthetists

• Clinical psychologists

• Clinical social workers

• Registered dietitians

• Nutrition professionals

• New FQHCs and RHCs (during the emergency period only)

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

A clinician must still be a Medicare "qualified provider." The initial waiver did not expand the list of eligible providers to provide services and be reimbursed

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Telehealth Waivers• Starting March 6, 2020 and for the duration of the COVID-19 Public Health Emergency,

Medicare will make payment for these visits in all areas of the country in all settings

• Reimbursement is allowed for any telehealth code, even if unrelated to COVID-19 diagnosis, screening, or treatment.

• These visits are considered the same as in-person visits and are paid at the same rate as regular, in-person visits

• Telehealth can be used for BOTH New and Existing Patients

• Physicians can reduce or waive cost-sharing for telehealth visits.

• Physicians licensed in one state can provide services to Medicare beneficiaries in another state. State licensure laws still apply.

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

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Additional Relevant Waivers“...HIPAA privacy regulations:

(a) the requirements to obtain a patient’s agreement to speak with family members or friends…

(b) the requirement to distribute a notice of privacy practices…and

(c) the patient’s right to request privacy restrictions or confidential communications.”

https://www.phe.gov/emergency/news/healthactions/section1135/Pages/covid19-13March20.aspx

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Controlled Substances & TelemedicineDEA-registered practitioners in all areas of the United States may issue prescriptions for all schedule II-V controlled substances to patients for whom they have not conducted an in-person medical evaluation [if]…

•The prescription is issued for a legitimate medical purpose by a practitioner acting in the usual course of his/her professional practice;

•The telemedicine communication is conducted using an audio-visual, real-time, two-way interactive communication system; and

•The practitioner is acting in accordance with applicable Federal and State laws.

https://www.deadiversion.usdoj.gov/coronavirus.html

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Telephone E/M VisitsIn a case where two-way audio and video technology required to furnish a Medicare telehealth service might not be available, there are circumstances where prolonged, audio-only communication between the practitioner and the patient could be clinically appropriate yet not fully replace a face-to-face visit.

For the duration of the PHE for the COVID-19 pandemic, Medicare will make separate payment for audio-only visits described by CPT codes 98966-98968 and CPT codes 99441-99443 as outlined on page 125 in the Interim Final Rule with Comment.

https://www.cms.gov/files/document/covid-dear-clinician-letter.pdf

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Virtual Visits• Brief communication service with practitioners via…communication technology modalities including

synchronous discussion over a telephone or exchange of information through video or image

• May respond to the patient’s concern by telephone, audio/video, secure text messaging, email, or use of a patient portal

• Initiated by the patient; however, practitioners may need to educate beneficiaries on the availability of the service prior to patient initiation

• “Not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment” (CPT® Code Description)

• Verbal consent required

• NEW New and Established Patients

• Cost-sharing (coinsurance and deductible) applies

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

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E-Visits• Patient initiated communication through an online patient portal.

• Individual services need to be initiated by the patient; however, practitioners may educate beneficiaries on the availability of the service prior to patient initiation.

• The patient must consent to receive virtual check-in services.

• Practice must have an established relationship with the patient.

• The Medicare coinsurance and deductible would generally apply to these services.

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Telehealth Options & Live Demonstration

PRESENTER: MEGAN FRANCIS, UPDOX

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Updox Inbox

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Invite Patient to join the visit by sending a text or email

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Provider View- waiting for patient to join

Once the patient is invited to join the visit they will have up to 10 minutes to join before the invitation expires.

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The patient receives a text message with a secure link to join the visit

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Patient Experience

Simple Controls will allow the recipient to pause video and audio, orend the chat if needed.

The entire Video Chat experience is streamlined to make things as simple as possible for the recipient.

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Video Chat Features

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Easily Capture Screen Shots for Documentation

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Control Features

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At the completion of the visit a summary can be sent to the Updox inbox

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Documentation Tips

PRESENTER: MAGGIE DELCAMP

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Medisoft Clinical & Lytec MD Users

Adding Updox Summary & Images to a Progress Note

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NextGen Office Users –

Minimal Configuration Required. Most are done in 1 hour.

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General Documentation ConsiderationsCHIEF COMPLAINT

• Acknowledge visit is telehealth.

• If using the 95 modifier, consider mentioning telehealth service due to COVID-19 pandemic.

• Document patient’s consent.

PHYSICAL EXAM

Avoid terminology that would indicate physical contact with patient.

• Auscultation

• Palpation

Sample Chief Complaints

The encounter is a telehealth session due to the COVID-19 pandemic. Patient was connected face to face using «*» for audio visual interaction. Patient was advised this encounter would be treated the same as a face to face billable visit and services will be submitted to their insurance company. Patient gave consent to this process.

OR

Due to COVID-19 pandemic, patient was seen via telemedicine with the patient’s consent.

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Selecting Appropriate Service CodeOn an interim basis, the policy to specify office/outpatient E/M level selection for telehealth visits has been revised.

• Removed any requirement for history or physical exam for codes 99201-99215.

Codes can be selected based on --

• MDM (Guidelines have not changed)

-OR-

• Time (There are new guidelines)

• Time is defined as all of the time associated with the E/M on the day of the encounter. (Time by the provider, not the staff)

• It does not have to be face to face and may or may not consist of counseling.

https://www.cms.gov/files/document/covid-final-ifc.pdf*See page 135-137 for the specifics

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Medisoft Clinical & Lytec MD Users Create a telehealth template in just a few minutes!

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Make the specific changes and additions you’d like to have included in your template.

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NextGen Office Users –Save Time with a Telehealth Blueprint

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Telehealth Billing Guidelines During theCOVID-19 National Emergency

PRESENTER: LOREE OLSEN

(877) 243-8881

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Telehealth Billing- Revised March 30, 2020NEW When billing professional claims to Medicare for all telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE), bill with:

• Place of Service (POS) equal to what it would have been had the service been furnished in-person

• 95 Modifier, indicating that the service rendered was actually performed via telehealth

• 80+ Covered Telehealth Services Added: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes

https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-04-03-mlnc-se

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POS 02 GuidanceWe note that we are maintaining the facility payment rate for services billed using the general telehealth POS code 02, should practitioners choose, for whatever reason, to maintain their current billing practices for Medicare telehealth during the PHE for the COVID-19 pandemic.

Note the difference in reimbursement between non-facility and facility for office visits.

CPT Non-Facility Facility

99201 45.56 27.07

99202 77.23 51.61

99203 109.35 77.23

99204 167.09 132.09

99205 211.12 172.51

CPT Non-Facility Facility

99211 23.46 9.38

99212 46.19 26.35

99213 76.15 52.33

99214 110.43 80.48

99215 148.33 113.68

https://www.govinfo.gov/content/pkg/FR-2020-04-06/pdf/2020-06990.pdfMedicare Fee Schedule https://www.cms.gov/apps/physician-fee-schedule/overview.aspx

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Other Telehealth Related ModifiersGQ Modifier– Service was furnished as part of a federal telemedicine demonstration project in Alaska and Hawaii using asynchronous (store and forward) technology.

GT Modifier– Service was furnished for diagnosis and treatment of an acute stroke.

CMS Clarified it IS NOT requiring the CR modifier on telehealth services.

April 3, 2020 MLN Newsletter: https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-04-03-mlnc-se

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COVID-19 Related Diagnosis Codes• Diagnosis of COVID-19: U07.1 (Effective April 1,2020) Use for Confirmed diagnosis only.

(For visits prior to April 1, 2020, report the code for the patient condition that is related to the COVID-19 (e.g., J12.89, “Other viral pneumonia”) and B97.29, “Other coronavirus as the cause of diseases classified elsewhere.” see New CDC Coronavirus Code Announcement for details)

• Known Exposure to COVID-19 Without Confirmed Diagnosis of COVID-19: Z20.828

• Possible Exposure to COVID-19 Without Confirmed Diagnosis of COVID-19: Z03.818

• Screening for COVID-19: Z11.59

• Suspected COVID-19: Assign the appropriate code(s) for each of the presenting signs and symptoms such as: • R05 Cough

• R06.02 Shortness of breath

• R50.9 Fever, unspecified

https://www.cdc.gov/nchs/data/icd/COVID-19-guidelines-final.pdf

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https://www.cdc.gov/nchs/data/icd/COVID-19-guidelines-final.pdf

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AMA Coding Guide- Updated April 3, 2020 Includes Changes Announced in the Interim Rule

https://www.ama-assn.org/system/files/2020-04/covid-19-coding-advice.pdf4/9/2020 AZCOMP.COM 45

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https://www.ama-assn.org/system/files/2020-04/covid-19-coding-advice.pdf4/9/2020 AZCOMP.COM 46

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Summary of Telemedicine Services

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

CPT 2020 Rate*

99421 (5-10 min) $15.50

99422 (11-20 min) $31

99423 (20+ min) $50

*Approximate national rate

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Cost Sharing: Modifier CSProviders are to apply modifier CS on applicable claim lines to identify COVID-19 testing-related services that are not subject to cost sharing under the Families First Coronavirus Response Act. Covered services include medical visits that that result in an order for or administration of a COVID-19 test; are related to furnishing or administering such a test or to the evaluation of an individual for purposes of determining the need for such a test. The effective date for modifier CS is for services performed between March 18, 2020 through the end of the Public Health Emergency.

For professional claims, physicians and practitioners who did not initially submit claims with the CS modifier must notify their Medicare Administrative Contractor (MAC) and request to resubmit applicable claims with dates of service on or after 3/18/2020 with the CS modifier to get 100% payment.

For institutional claims, providers, including hospitals, CAHs, RHCs, and FQHCs, who did not initially submit claims with the CS modifier must resubmit applicable claims submitted on or after 3/18/2020, with the CS modifier to visit lines to get 100% payment.

https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-04-07-mlnc-se

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Collecting From Patients Remotely

PRESENTER: TONY PETERSON, NEXTRUST INC.

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Maintaining Patient Billing & Payments During Social Distancing• Medicare deductibles and co-insurance STILL APPLY to telehealth visits (other payers may vary)

• Many patients still have HSA/FSA funds available for healthcare needs

• In order for a practice to function, you must continue to generate revenue (GET PAID FOR YOUR WORK)

• BillFlash allows you to send statements to patients, and receive payment from them, without anyone having to leave their homes

• BillFlash is integrated into many different EHR/practice management software packages

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Collect Payments Online with Billflash• Pre-Visit Charges: Allows you to email a charge to patients which allows them to pay online prior to a telehealth visit

• Post-Visit Electronic Statements (eBills): Allows you to send same-day statements to patients via electronic delivery methods

• Payment Plans: Allows you to set up AUTOMATIC, recurring billing, starting on the date you select, with full PCI compliance

• Automatic Payments: Allows you to set up automatic payments when the statement is sent to the patient (also PCI compliant)

• Stored Payment Methods: Lets you securely store payment methods for future payments

Note: Direct integration with Medisoft and Lytec

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One Platform for Smarter Billing

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Subscribe or Check the Blog Often forthe Most Up to Date COVID-19 Related News

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https://www.azcomp.com/blog/

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Favorite Resources to Check OftenNear Daily Updates: https://www.cms.gov/newsroom

MLN Matters Articles: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles (Subscribe to the Mail list here)

CDC Guidance: https://www.cdc.gov/coronavirus/2019-ncov/communication/guidance-list.html

CMS COVID-19 Stakeholder Calls: https://www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/PodcastAndTranscripts

AMA COVID-19 Page: https://www.ama-assn.org/delivering-care/public-health/covid-19-2019-novel-coronavirus-resource-center-physicians (Special Coding Guide to COVID-19 click here)

Highly Recommend Reading CMS Letter sent 4/7/2020: Dear Clinician

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Special Limited Time Offers Exclusively through AZCOMP- call (877) 243-8881

Send Mailed & eBill Statements

Free for 30 daysPay only the cost of a stamp

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That’s all, folks!

Give us a call (877) 243-8881

Or visit us at: www.azcomp.com

Or email us at: info@azcomp.com

Interested in another webinar?

Check out: www.azcomp.com/events

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