COVID-19 Policy Updates - CMS Increases Telehealth Flexibility: Physicians and Other Clinicians

On April 30th, 2020, CMS released temporary changes which directly affect the delivery of telehealth. 

In the ruling, CMS states “clinicians can now provide more services to beneficiaries via telehealth so that clinicians can take care of their patients while mitigating the risk of the spread of the virus. Under the public health emergency, all beneficiaries across the country can receive Medicare telehealth and other communications technology-based services wherever they are located. Clinicians can provide these services to new or established patients. In addition, health care providers can waive Medicare co-payments for these telehealth and other non-face-to-face services for beneficiaries in Original Medicare.”

Organizations that had the  structure to bill for RPM prior to the April 30th updates, now qualify for more codes, detailed below. The new codes allow for Medicare billing even if the patient is only on telehealth for a few days, and allow billing for codes that previously had a limit. These new changes will enable more efficient delivery of telehealth and RPM to patients with and without COVID-19 diagnoses.

Qualified Providers 

Clinicians can provide remote patient monitoring services to both new and established patients. These services can be provided for both acute and chronic conditions and can now be provided for patients with only one disease. For example, remote patient monitoring can be used to monitor a patient’s oxygen saturation levels using pulse oximetry. (CPT codes 99091, 99457-99458, 99473-99474, 99493-99494) 

Medicare has broadly waved the restrictions they had previously placed on who can bill for telehealth. Before, Medicare provided a list of acceptable professionals. Now, CMS has stated that “anyone eligible to bill Medicare for their professional services” (E&M Codes) can bill telehealth services.

• Prior to 4/30/20: “The physician or practitioner at the distant site must be licensed to furnish the service under State law. The physician or practitioner at the distant site who is licensed under State law to furnish a covered telehealth service described in this section may bill, and receive payment for, the service when it is delivered via a telecommunications system”
• 4/30/20: For the duration of the COVID-19 pandemic, physical therapists, occupational therapists, speech language pathologists, as well as others already eligible to bill Medicare for professional services, may provide Medicare telehealth services.

Frequency Limitations

Current CPT coding guidance states that the remote physiologic monitoring service described by CPT code 99454 (device(s) supplied with daily recordings or programmed alerts transmission each 30 day(s)), cannot be reported for monitoring of less than 16 days. For purposes of treating suspected COVID-19 infections, Medicare will allow the service to be reported for shorter periods of time (2 days or more) as long as the other code requirements are met. 

Per the removal of frequency limitations on Medicare telehealth,  the following telehealth services no longer have limitations on the number of times they can be provided:

• A subsequent inpatient visit can be furnished via Medicare telehealth, without the limitation that the telehealth visit is once every three days (CPT codes 99231-99233); 
• A subsequent skilled nursing facility visit can be furnished via Medicare telehealth, without the limitation that the telehealth visit is once every 30 days (CPT codes 99307- 99310)
• Critical care consult codes may be furnished to a Medicare beneficiary by telehealth beyond the once per day limitation (CPT codes G0508-G0509)
  • For example, prior to the COVID-19 PHE, a critical care consult could only be billed once per day. Now, if a patient needs more than one consultation (due to worsening symptoms or other reasons), the clinician can bill for it as well.
    
    

Eligible providers are now able to bill CMS more frequently for care furnished to suspected or confirmed COVID-19 cases. This allows providers to bill for the extra care needed for COVID-19 patients. 

Home Health Agencies: 

The new CMS changes allow for telehealth to be used to avoid previously required in person encounters.This will allow for maximizing coverage if there are limited physician and advanced practice clinicians, and will allow those clinicians to focus on caring for patients with the greatest acuity. 

Initial Assessments: By waiving 42 CFR § 484.55(a), home health agencies can perform initial assessments and determine patients’ homebound status remotely or by record review, when previously they were required to perform the initial assessment in person. This will allow patients to be cared for in the best environment for them while supporting infection control and reducing impact on acute care and long-term care facilities.

Home-bound Definition: A beneficiary is considered home-bound when their physician advises them not to leave the home because of a confirmed or suspected COVID-19 diagnosis or if the patient has a condition that makes them more susceptible to contract COVID-19. As a result, if a beneficiary is home-bound due to COVID-19 and needs skilled services, an HHA can provide those services under the Medicare Home Health benefit. 

Read more about how CMS’ recent rulings affect home health agencies, here.

Long Term Care Facilities: 

Medicare Telehealth • Physician visits in skilled nursing facilities/nursing facilities: CMS is waiving the requirement in 42 CFR 483.30 for physicians and non-physician practitioners to perform in-person visits for nursing home residents and allow visits to be conducted, as appropriate, via telehealth options. 

Read more how CMS’ recent rulings affect long-term care facilities, here.

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If you have any questions about these recent changes, or about how HRS clients are pursuing reimbursement for telehealth, please reach out to our reimbursement team at reimbursement@healthrecoverysolutions.com.