How Does COVID-19 Telehealth Expansion Affect Providers?

UPDATED April 7, 2020: There have been updates to the proposed rule which can be found here. 

Telehealth services have become even more critical in caring for patients as the COVID-19 pandemic quickly evolves. In order to temporarily remove barriers to practice telehealth, the Federal Government and many States are making 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?

• Mar 6, 2020, is 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?

CMS has long imposed coverage restrictions on where a patient can be located – 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) 
• 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 rulemaking (2019 and 2020) which use communication-based technology (CBT) by nature, and thus do not have geographic site nor originating site restrictions; examples of these codes are: 

• Virtual Check-Ins 
• Store and Forward (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 his/her practice.

What has changed for Patients?

Under the Waiver, the OIG 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?

• Place of Service “02” on all telemedicine claims
• When billing Medicare: Only CAHs billing under Method II should use Modifier “GT;” any non-CAH Method II providers will have their claim rejected for Modifier “GT”
• When billing Commercial Insurance: append Modifier “95” to claims
• Only eligible to bill Originating Site Fee (Q3014) when 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 AMA.

What action is being taken by the States?

While the States’ responses are varied, many of the states 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. 

Your HORNE Healthcare team is ready to help you as additional legislative changes continue to evolve. For more information, please contact our HORNE team.