FAQ: COVID-19 Telehealth Reimbursement

By Gerald Buggs, MSJ

As the COVID-19 outbreak continues to evolve, CMS has been updating their policies regarding telehealth delivery. We asked our clients to submit their questions relating to the many changes and updates.

Our reimbursement team answers the questions below.

Telehealth Reimbursement Questions

Q: Can you please tell us code numbers for NP and then RN that we can be paid for. Also please include any documentation requirements for each that are needed to ensure reimbursement.

A: The standard codes for Remote Patient Monitoring (RPM) are 99453, 99454, 99457 and 99458. These codes are for RPM services and were available prior to the COVID-19 outbreak. CPT Code 99453 is for the initial set-up, 99454 is the supply of the device, collection, transmission and report/summary services to the clinician. CPT Codes 99457 and 99458 are the remote physiologic monitoring services by clinical staff/MD/QHCP.

These codes require general supervision by an MD or NP. The codes are for Part B services and are billed on a 1500 form using the NPI number of supervising QHCP either an MD or NP. NP’s also have the opportunity to bill E&M codes 99201 to 99215.

Q: For F2F encounters related to CMS' requirement that a home health (HH) patient has to have had a F2F encounter with a MD or NPP either 90 days prior to our HH SOC or 30 days after our SOC, CMS is now allowing these encounters to occur in the patient's home via a telemonitor, etc. This is part of the waiver Congress just passed. In order for a HHA to do this, would we allow a physician or NPP to download our "Patient Connect" app? The patient would then be placed on a monitor and the encounter would occur under this method? There is no reimbursement set up under this arrangement. What we are trying to do is meet the regulation.

A: With the HRS platform you have access to create “ClinicianConnect” logins for unlimited users who will all be able to perform virtual visits and monitor vital signs for patients. If you have an MD or NP that is part of your organization, they can easily perform the F2F encounter through the ClinicianConnect Portal.

For MDs or NPs that are not part of your organization, we recommend creating a “subgroup” that would only allow them access to their patients. That way, they can still use the ClinicianConnect portal to perform virtual visits. In some cases, you can even charge a PMPM rate to these groups to compensate for providing the RPM and telehealth software to their patients.

Given the lifting of restrictions on HIPAA violations, as long as you are acting in “good faith” to provide care to patients during the outbreak you will be allowed to provide access to your broader patient list to the MDs and NPs who need access to their patients.

Q: Do you know when or if Medicare will reimburse RNs to perform Telehealth video visit assessment at home for our patient on home health and hospice?

A: As of right now a telehealth video visit will not count towards the LUPA requirement for HH and Hospice. However, we do expect this change to happen in the near future. Our best recommendation right now is to prepare your EMR to be able to include virtual visits as part of the billing report to submit to CMS. This way you’ll be ready to hit the ground running when this change comes into effect.

Q: Can Telehealth visits be made for palliative care consult visits by NPs & what codes should be used?

A: Yes, palliative care consult visits can be performed by NPs through telehealth. With the waivers in place by CMS for Telehealth services no restrictions for where the patient is located or rural indicator, the NP can bill E&M codes 99201-99215 or the RPM codes of 99453, 99454, 99457 and 99458.

Q: Do video or telephonic visits count as any other visit for PDGM expected number of visits?

A: Agencies can explore supplementing visits with telehealth and telemonitoring when appropriate. As of right now these visits do not count as actual visits towards the LUPA requirement but we do expect this change to happen in the near future.

Q: The ability to do remote visits, when clinically appropriate, applies to all disciplines (nursing and rehab)?

A: The ability to do remote visits when clinically appropriate does apply to all disciplines during the pandemic of COVID-19. However keep in mind that not all remote visits will be reimbursable depending on the setting and discipline among other factors.

Q: Does this waiver have an end date, or is it open at this time pending on the development of COVID-19?

A: There is no documentation stating an end date. The waivers are in place as long as the President has the Emergency Declaration in effect.

Q: Have you heard any updates regarding home health and if we will be able to count telephone visits as a billable visit under our Medicare part A billing.

A: No, at this time we are not aware of any updates concerning home health agencies being able to bill for telephone visits under Medicare Part A.

State Specific

Q: We wish to know specifically if there are mechanisms for home health agencies to secure reimbursement for RPM and video consultations through Medicare. Do we foresee any emergency measures on the horizon in light of this pandemic? In Maine, we have a structure for reimbursement under MaineCare.

A: As of right now telehealth video visits are not reimbursable for home health agencies. We do foresee this changing in the very near future and we will be updating our customers as soon as reimbursement options are available through Medicare for Home Health telehealth. Right now telehealth visits are only reimbursable for QHCP such as MDs or NPs.

Please keep in mind your commercial carriers are given the flexibility to structure Telehealth/RPM reimbursement to meet their business needs.

Q: I understand that the telehealth visits that are performed by anyone with a provider number will be reimbursed (MD, APN , MSW). In New Jersey APN aren't even recognized in home care - have to work as a RN- , so where does reimbursement stand for a registered nurse performing a video visit with a patient? Also I don’t see anything about remote telemonitor readings getting reimbursed.

A: Telehealth means the use of information and communication technologies, including telephones, remote patient monitoring devices or other electronic means to support clinical healthcare, provider consultation, patient and professional health related education, public health, health administration and other services.

CMS has waived the originating site allowing the patients home to be an authorized site for telehealth services and also waived the rural site location allowing patients to receive services wherever they are located. However, as of right now telehealth video visits are not reimbursable for home health agencies. We do foresee this changing in the very near future and we will be updating our customers as soon as reimbursement options are available through Medicare for Home Health telehealth. Right now telehealth visits are only reimbursable for QHCP such as MDs or NPs.

Remote Patient Monitoring services can be administered by an RN, LPN or other QHCP for remote patient monitoring codes 99453, 99454, 99457 and 99458. These codes require general supervision and are billed under the NPI number of the supervising QHCP MD or NP.

 

If you have questions or comments, please contact our reimbursement team at reimbursement@healthrecoverysolutions.com

Tags: reimbursement, COVID-19

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