Over the past couple of weeks, CMS has communicated multiple modifications to telehealth service provisions and payments to benefit both providers and patients. To date, these requirements are only in effect for the duration of the national emergency as it relates to the COVID-19 pandemic.
CMS defines three types of telehealth visits as follows:
Telehealth Visits: Use of two-way telecommunication technology for office visits, hospital visits and other services that generally occur in person. These are paid at the same rate as regular, in-person visits.
CPT® Codes: 99201 - 99205, G0425 - G0427, G0406 - G0408
E-Visits: Patient-initiated communication via patient portals.
CPT® Codes: 99421 - 99423, G2061 - G2063
Virtual Check-Ins: Brief (5-10 minutes) communication with a patient about an established condition via synchronous technology such as a messaging app, telephone or email.
CPT® Codes: G2012, G2010
The following requirements have been waived temporarily during the current national emergency:
- Distant and originating site requirements: The patient and the provider may be in virtually any location, including their own homes during the provision of these services.
- Established patients: Providers may see new patients during this time, which wasn't previously allowed under telehealth regulations.
- Practicing over state borders: During the public health emergency, providers may provide telehealth services to patients in other states without being certified in the state in which the patient is currently located.
- Health Insurance Portability and Accountability Act: The HHS Office for Civil Rights (OCR) will waive penalties for HIPAA violations against health care providers that serve in good faith through everyday communication technologies such as FaceTime or Skype.
While the information above is from CMS, many major payors have opted to follow this guidance as well.
Additional information for Rural Health Clinics and Federally Qualified Health Centers is forthcoming.