San Francisco announced its stay-at-home order on March 17 to combat the evolving COVID-19 pandemic. In response to public health guidance on social distancing, CMS is reducing many of the barriers to the rapid implementation of telehealth under the 1135 waiver authority and the Coronavirus Preparedness and Response Supplemental Appropriations Act. The primary goal is to continue the provision of medical care while limiting the viral exposure of patients, staff, and providers.
A Summary of the Key Changes to Telehealth
Below is a listing of some of the key changes CMS is implementing to facilitate telehealth services under Medicare. These changes will be effective for services performed on March 6, 2020 through the duration of the national state of emergency. During this period:
- Services in an office, hospital, and/or other setting inclusive of the patient’s home qualify for reimbursement
- Telehealth may be utilized for either new or established patients to the practice
- Synchronous audio/visual telecommunication is required for telehealth visits
- Telehealth services reimbursement will not be limited to patients in designated rural areas
- Telehealth services reimbursement will increase to the level of an in-person visit and providers will have the flexibility to waive deductibles and/or coinsurance
- Eligible Providers include physicians, nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologists, social workers and others
- Services may include evaluation and management visits, preventive health visits, and mental health services.
- HIPPA violations may be waived for providers communicating with technologies that pose security concerns
- Prescription of scheduled II-V medications via telehealth are subject to federal and state laws and other requirements
Virtual Check-Ins and E-visits
In 2019, prior to telehealth expansion due to COVID-19, CMS began reimbursing providers for virtual check-ins and E-visits. CMS defines a virtual check-in as a short patient-initiated communications with a healthcare provider and a E-visits as non-face-to-face patient-initiated communications through an online patient portal.
While such telehealth visits are similar in some ways, there are some differences. Below are a few of the factors to keep in mind when considering reimbursement for virtual check-ins and E-visits.
- Virtual check-ins and E-visits are for established patients of the practice
- Patient must consent to both virtual check-ins and E-visit services and for E-visits, the patient must initiate the communication with the practice
- Telephone check-ins are paid using HCPCS codes G2010-G2012 (following all CMS coding guidelines and requirements), and responses from the provider may include a telephone call, patient portal, text, email, and/or video conference
- E-visits through a patient portal are paid using HCPCS codes G2061-G2063 (for non-physician healthcare professionals) or CPT codes 99421-99423 for evaluation and management services (following all CMS coding guidelines and requirements)
- Neither virtual check-ins or E-visits are eligible for reimbursement if related to a medical visit within the previous 7 days or if the patient seeks medical services within 24-hours of the check-in or visit
For more information on telehealth and transaction advisory services pertaining to telehealth provision and equipment, we encourage you to contact one of our experts today.
Don Crawford, Partner
Joe Aguilar, Partner
Natalie Bell, Director
Rob Holland, Director
The information provided herein is accurate as of the date of entry and relies on data available at the time of writing. Given the rapidly changing environment, the information provided is intended as a resource only and should not replace direct consultation of relevant laws, policies, and guidelines. HMS Valuation Partners is committed to ensuring that clients have accurate and up-to-date information and is closely monitoring any changes in policy and practice relevant to COVID-19.
