Elizabeth Woodcock, founder and principal of Woodcock Associates and executive director of Patient Access Collaborative, presented a webinar Dec. 10 on the topic, “Telehealth 2021: Reimbursement Updates & Predictions.” To watch the full webinar, click here.
The following are some of the key points from the webinar and Q&A between webinar attendees and Woodcock.
- Telehealth is here to stay. Roughly 20 percent of all medical visits in 2020 were conducted by telemedicine. Although the percentage may vary widely based on specialty, practice size, and geography, Woodcock said that percentage looks to hold in 2021. The most fundamental principle in healthcare is that only services that are evidence-based are provided, and given telehealth’s explosion of use since March 2020, there is plenty of data and evidence piling up for researchers to compile. Prior to providers innovating with the use of telehealth in March, the digital tool’s use was less than one percent. “If we can gather the evidence that it works, regulatory and payers will follow because of the evidence,” Woodcock said.
“I think the genie is out of the bottle on this one,” stated Seema Verma, Centers for Medicare and Medicaid Services (CMS). “I think it’s fair to say that the advent of telehealth has just completely accelerated … but there’s absolutely no going back.”
- How did telehealth become a public health issue? The U.S. government, in the absence of Congressional action, doesn’t really have the authority to take the genie out of the bottle. What made telehealth services available to the public from a regulatory and provider reimbursement standpoint was the coronavirus pandemic itself, Woodcock said. That’s because it triggered a public health emergency (PHE), which is critical because the definition of telehealth is tied to the PHE. That opened the door for healthcare organizations to essentially ignore previous originating circumstances that governed the use and billing of telehealth. The PHE allowance for telehealth is set to expire Jan. 21, 2021, but Woodcock said it’s anticipated that Congress will extend the allowance until March and likely even until July since so many Americans will still be receiving the COVID-19 vaccination well into the New Year.
- Medicare and reimbursements. When it was obvious that telehealth might be the only avenue to provide care for many providers, Medicare and Medicaid started to change their definitions on previous conditions for requirement that included location, device, services, provider, payment and relationship. Before the COVID-19 crisis, CMS included 70 to 80 services. Currently, there are almost 300, Woodcock said. The PHE changed all the requirements to allow telehealth.
- Competitive landscape. Another issue that health organizations need to stay on top of is that competition is heating up. Insurers are partnering with telemedicine companies to provide services to patients free of charge. Likewise, major corporations, including Amazon, Walmart, Best Buy, CVS and others, are wading into the telehealth provider space increasing the competition for your billable services. Why should you care? Because it means that the relationship between payers and employers equates to putting them in the driver’s seat, Woodcock said. If patients can get their telehealth services for free, why should they be charged a copay to come to a traditional healthcare provider? With big money involved, it changes the paradigm of referrals for care. It means providers must ensure they extend easy-to-use telehealth and virtual health patient communication and engagement services for a positive patient experience.
- What’s not telehealth? Some new virtual health services available to patients, including virtual check-ins, eVisits, and remote patient monitoring are similar to telehealth but are able to skate around the Medicare regulations. Because they are considered “communication-based technology services,” they are not held to the same restrictions as telehealth and thus patients aren’t required to make a copayment to use these free services. CMS is making it clear that providers can use other technology tools to augment telehealth to improve patient care and communication.
Q&A with Elizabeth Woodcock
Q: For the CS modifier to be used, what if you are following up on a patient who had a COVID test on another date of service, can you still use the modifier on follow up visit?
A: Please see pages 5 & 6; my interpretation is that you could not use the modifier on subsequent encounters. https://www.cms.gov/files/document/FFCRA-Part-42-FAQs.pdf.
Q: Is there a source that aggregates the data from the different payers regarding cost-share waivers?
A: No, however, this portal is valuable – it requires culling through, but it’s all there:
Q: During PHE can we bill inpatient E&M services via audio only? If so, anything special about the documentation?
A: These codes are not listed as “Can Audio-Only Interaction Meet the Requirements?” See link:https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes. However, you may want to review the requirements for these codes, which are the “phone” codes: 99441, 99442 and 99443.
Q: Is the two-day rule all remote physiologic monitoring or only COVID-19?
A: According to CMS, “Current CPT coding guidance states that the remote physiologic monitoring service described by CPT code 99454 (device(s) supply 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 than 16 days as long as the other code requirements are met.” See page 5: https://www.cms.gov/files/document/covid-19-physicians-and-practitioners.pdf
Q: Can telehealth be used for annual wellness exams specifically for Medicare Advantage participants? Thinking how to impact the HCC/RAF scores.
A: AWV are included as a covered telemedicine service. Download the list here: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes They can even be performed by phone only.
Q: Would the CS modifier apply to psychotherapy CPTs 90832, 90834, 90837 and 90853?
A: Please see pages 5 & 6; the CS modifier is used when a COVID test is administered or ordered. I don’t know if you are ordering tests during psychotherapy, but if you are, it may be applicable. https://www.cms.gov/files/document/FFCRA-Part-42-FAQs.pdf.
Q: With regard to G2212 - I get that that adds on to 99205 or 99215. Is it true 99358/59 can no longer be associated with an outpatient office visit on separate day of service? CMS seems to have stated they can't be used anymore.
A: I believe that they are still active, valid codes (for non-face-to-face prolonged care). However, as you note, G2212 is new and applicable to coding prolonged services (in 15-minute increments).
Q: Can you explain how direct supervision can practically be provided via telemedicine? Does the MD have to be on the phone/video with the patient and the PA?APRN?
A: See page 6: https://www.cms.gov/files/document/covid-19-physicians-and-practitioners.pdf. Per CMS, “Medicare Physician Supervision Requirements: For services requiring direct supervision by the physician or other practitioner, that physician supervision can be provided virtually using real-time audio/video technology.”
Q: Regarding the CS modifier, it’s my understanding that specific dx codes must be used as well. Is that correct?
A: Please see pages 5 & 6; the CS modifier is used when a COVID test is administered or ordered. I am not aware of any specific diagnosis(es) codes required. (There are for the HRSA uninsured claims, but not for this program, to the best of my knowledge.) https://www.cms.gov/files/document/FFCRA-Part-42-FAQs.pdf
To learn more about telehealth reimbursement and predictions for 2021, watch the entire webinar here.