How Does Covid-19 Telehealth Expansion Affect Providers?

Questions and answers for quality health providers

Published: Wednesday, April 22, 2020 - 12:01

Telehealth services have become even more critical in caring for patients as the Covid-19 pandemic quickly evolves. To temporarily remove barriers to practice telehealth, the federal government and many states have made sweeping changes in telehealth waiver provisions.

As HORNE continues to closely monitor the impact of legislative responses to the Covid-19 public health emergency, here are a few questions and answers you need to know.

What are the critical dates in the waiver?
• March 6, 2020, was the effective date of all provisions
• Provisions will remain in effect until the public health emergency is declared to be at an end

What are the most notable changes impacting healthcare delivery?
The Centers for Medicare and Medicaid Services (CMS) have long imposed coverage restrictions on where a patient can be located—called the “originating site.” Prior to the waiver, the originating site was required to be a healthcare facility, located in one of the following:
• A rural area (outside of an MSA)
• A health professional shortage area

Under the waiver, a patient’s home or any setting of care is now a qualified originating site, and there are no geographic restrictions as on the originating site. These new provisions are not limited to Covid-19 treatment—that is, they apply to the treatment of all patients within the scope of respective physician practices.

Are there any new procedure codes or services added by the waiver?
No. The waiver simply allows expanded originating site coverage for services already covered. Medicare maintains a list of services that can be conducted via telemedicine “as a substitute for in-person services.”

In addition, CMS has set forth certain procedure codes in prior rule-making (2019 and 2020) that use communication-based technology by nature, and thus do not have geographic site or originating site restrictions. Examples of these codes are:
• Virtual check-ins
• Store and forward (e.g., patient-generated image or video)
• E-visits (online digital E/M)

Note: These three classes of procedures require an established patient-provider relationship. Under the waiver, CMS states that it does not intend to audit this requirement, clearing the way for new patients to receive these services.

Are there any changes to the types of practitioners who can deliver services via telehealth?
No. Generally, the types of practitioners covered are those with privileges to bill Medicare separately for any procedure within the scope of their practices.

What has changed for patients?
Under the waiver, the Office of Inspector General has allowed providers to either reduce or waive cost sharing by beneficiaries. Patient outreach will be key as it relates to the increased availability and lower cost of services.

Are there any billing considerations?
• Include Place of Service “02” on all telemedicine claims.
• When billing Medicare: Only critical access hospitals (CAHs) billing under Method II should use the modifier “GT”; any non-CAH Method II providers will have their claim rejected for modifier GT.
• When billing commercial insurance: Append the modifier “95” to claims.
• Facilities are only eligible to bill originating site fee (Q3014) when a patient is located in a qualified healthcare facility. As noted, geographic restrictions do not apply under the waiver.

What is the expected reimbursement on claims?
Payment parity requires Medicare to pay the same rate for services covered via telehealth as if those services were delivered in person. Communication-based technology services carry separate CPT or G code reimbursement—as codified by the American Medical Association (AMA).

What action is being taken by the states?
Although the states’ responses are varied, many have lifted cross-border licensing restrictions. These restrictions require practitioners delivering care via telemedicine to carry licensure in the state where the patient is located.

First published March 26, 2020, on the Horne Healthcare blog.

About The Author

Clinton Ballew

With a Bachelor of Accounting and Finance from the University of Alabama at Birmingham, and a Master of Taxation from the University of Alabama, Clinton Ballew is a manager in healthcare reimbursement and advisory at HORNE LLP. Ballew specializes in state healthcare financing models, cost reporting, telemedicine reimbursement, and other consulting engagements.