Telemedicine and COVID-19 FAQ
Telehealth policy can be a complicated issue.  This past week we have been getting a lot of questions: “How will I get reimbursed?” is a frequent one, along with “How do I see patients in other states?”

The coding and reimbursement rules for telehealth changed fast in March and will continue to have changes in April.  Below are some of the major changes that occured in March: 

  • March 6 - Congress passed a law relaxing certain telemedicine restrictions during the government state of emergency.
  • March 13 - President Trump declares National Emergency
  • March 17 - 10 days later CMS releases rules on billing for telehealth and reminds practices of other non-face-to-face services that can be reported.

This article/FAQ will provide tips to refine your Telehealth practice workflow, answers to general Telehealth, and some links for coding/billing for Telehealth during COVID-19. Events are constantly evolving. Keep in mind that links to documents provided below should be considered as living - Information is frequently changing as new policies become available/ enacted. 
How can I streamline my workflow for my telehealth practice ? 

Here are a few things you can do to streamline your workflow:

  • Inform your patients know that you are now offering telehealth services when they call your office. 

  • Consider reaching out to the payer prior to the appointments to discuss telehealth coverage, even if temporarily due to current events.
  • Send patient prior instructions on how to prepare for a televisit.

  • Ensure you are continuing to properly document these visits in Charm as you normally would with an in-person visit. This will keep the patient’s medical record together, allow for consistent procedures for ordering testing, medications, etc. and support billing for telehealth visits.
 
  • Obtain patient consent prior to any recording of the encounter. Once the form is signed and submitted in Charm, the form will stay in the Patient’s record.

  • Repurpose your staff to assist in the back end functions. Consider having your staff
  • Proactively do patient outreach
  • Test connectivity and be available for technical issues prior to the appointment inorder to stay on-schedule for the day
  • Obtain past medical, social, etc. health history prior to the visit
  • Reconcile medications

In redesigning your workflow, you may want to consider the following - reducing your hours, rescheduling non-essential in-person appointments, triaging calls and repurposing cancellations.
 
Is Charm Health really Free? How fast can I get this enabled? 

Charm health is offering free Telehealth until July 2020. Charm Telehealth is HIPAA compliant and integrated with it’s EHR. Charm Health has a turn around time of 12 hours or less to get you setup for Telehealth. It is a great time to start a telemedicine practice; there is a lot of support available from Charm support and in the online digital community. 

Do I need to have a medical license in the state where the patient is located?

While Human Health Services has waived the need for a provider to have a medical license in the state where the patient is located, individual states must approve the waiver.  
The best advice is to check with your state laws. You can do this by reaching out to your state board and see if they have issued a state waiver.

Do I need to get additional Malpractice Insurance for Telehealth?

Check with your malpractice Insurance carrier if they already cover telemedicine services. Telemedicine is still considered risky by most insurance carriers, although a low liability. Check with your malpractice carrier as there may be additional forms to complete. Sometimes malpractice insurance for telemedicine will increase the policy’s cost, but not always. If your current malpractice insurance doesn’t carry telemedicine, start researching companies that do offer it. 

Do I collect copay / deductibles for Telehealth visits?
 
1.   Medicare beneficiaries are liable for deductibles and copays - but HHS/CMS is providing flexibility for providers to reduce or waive cost sharing during COVID-19

2.   Check with the specific payer to see if there are any limitations on telemedicine coverage. You can also choose to waive the copay based on the need of the patient as an act of goodwill if finances are an issue.

3.   You can find the latest information regarding specific insurance coverage regarding cost-sharing, deductibles etc. in the link below:

What is the place of service and modifier for telemedicine?  
 
As rules are constantly changing, please check the following   link for the latest information.

How do you code for a visit? 
Visits are coded by diagnosis and what the provider has done. Rules are very similar to what would be done for in-person visits. 
 
Charm has put together a helpful set of Dx and CPTs for quick access. Please see:







How much will we be paid? Is it the same as if it were face to face service?
 
CMS was originally going to use facility rates, which is lower. Now if you use POS 11, offices are paid at the non facility, higher rate. 

CMS has released a video detailing Medicare Coverage and Payment of Virtual Services .
 
Other payer policies will vary, depending on what you bill . For specific health insurance providers, see here:

I am confused about when to use 95 vs GT as a modifier -- can you clarify?
 It seems CMS is asking point of service to be listed as "11" (non-facility), but private insurances are asking for it to be "02" or "telehealth" -- which is this correct?
How do I document a Telehealth Visit?
What kind of Telehealth services are covered specific to Medicare?
Disclaimer: Charm Health assumes no responsibility or liability arising out of the application or use of any information, product, or service described herein except as expressly agreed to in writing by Charm Health. Charm Health customers are advised to obtain the latest information on the CMS website and other primary sources before relying on any published information.

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