Yesterday, the Centers for Medicare & Medicaid Services (CMS) broadened access to Medicare telehealth services to enable beneficiaries to receive a wider range of services from their doctors without having to travel to a healthcare facility. You can read the full release here.
The release discussed three types of visits that are reimbursable by the CMS for services ddelivered via telehealth:
- Medicare Telehealth Visits
- Virtual Check-Ins
While on the surface this was good news for therapists, it is important to note that only e-visits apply to physical therapists at the time of this writing. It is also important to note that e-visits are not telehealth visits. At the time of this writing, the CMS is not reimbursing for telehealth visits performed by physical therapists.
So, what is an e-visit? The release referenced above defines an e-visit as:
“In all types of locations including the patient’s home, and in all areas (not just rural), established Medicare patients may have non-face-to-face patient-initiated communications with their doctors without going to the doctor’s office by using online patient portals. These services can only be reported when the billing practice has an established relationship with the patient”
What are the important restrictions noted there? Per the release, here are some key takeaways:
- These services can only be reported when the billing practice has an established relationship with the patient.
- This is not limited to only rural settings. There are no geographic or location restrictions for these visits.
- Patients communicate with their doctors without going to the doctor’s office by using online patient portals.
- 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 services may be billed using CPT codes 99421-99423 and HCPCS codes G2061-G206, as applicable.
- The Medicare coinsurance and deductible would generally apply to these services.
Medicare provided the following guidelines for billing for these e-visits in the release:
Clinicians who may not independently bill for evaluation and management visits (for example – physical therapists, occupational therapists, speech language pathologists, clinical psychologists) can also provide these e-visits and bill the following codes:
- G2061: Qualified non-physician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the 7 days; 5–10 minutes
- G2062: Qualified non-physician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 11–20 minutes
- G2063: Qualified non-physician qualified healthcare professional assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 21 or more minutes.
Important note on HIPAA:
This release from the CMS waived the requirement to use HIPAA compliant video conferencing software during the COVID-19 national health emergency. Read below from the release:
HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (HIPAA):
Effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency. For more information: https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/index.html
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