Ever-changing Telehealth Rules during COVID-19

Donna White

Donna White

By Donna White, Principal Consultant and Owner of Legacy Consulting Services and Legacy Billing Solutions in Montgomery, Alabama.

We are most certainly living in uncertain times. The healthcare field looks nothing like it did a month ago. And things seem to be changing daily, essentially because they are!

When a stress was put on Social Distancing a few weeks ago, the question started to become – how do I visit my doctor’s office? Particularly if my ailment does not have anything to do with COVID-19? A patient doesn’t want to put him or herself at risk for catching the virus if they just need to talk to a doctor about a possible UTI or kidney infection. And what about mental health? You’re talking close quarters in both waiting rooms and typically offices.

The Centers for Medicare and Medicaid Services (CMS), has historically had very strict and unmoving with telehealth guidelines. They quickly stepped up to relax many of their guidelines to make patient care an additional way to practice Social Distancing. However, doctor’s offices have had to move quickly and stay on top of ever-changing guidelines of how to bill these services.

As of March 31, 2020, CMS changed up their billing guidelines for telehealth. Originally you had to bill a Place of Service (POS) 02 and add no modifier. As of yesterday, they changed that to now bill a POS of 11 (Office) with a modifier 95 to indicate telehealth. This is effective back to March 01, 2020 – so make sure to re-bill your Medicare claims. Why? They made this change because providers are reimbursed at a lower rate with POS 02 vs. POS 11. Make sure your practice is not leaving money on the table by not re-billing these claims promptly.

For established patients, there is a Virtual Check-In that can be billed for a brief check in (5 – 10 minutes), via telephone or other telecommunications. NOTE: This is the ONLY instance where a telephone only visit can be billed for Medicare at this time. Also, many commercial insurances are not covering telephone only visits at all.

There has also been a relaxation of the equipment used for video conferencing to include normally not covered programs like Skype or Facetime. Patients do still need to either sign or verbally agree to a telehealth communications waiver.

Commercial payors are following suit where they can, but their rules are changing regularly as well. We recommend appointing someone in your office to check payor websites every morning to ensure there have been no changes to their regulations overnight. Each payor like Blue Cross Blue Shield, Aetna, Cigna, Tricare, Humana, etc. all have a COVID-19 section in the provider area on their website that is regularly updated.

Navigating in this changing environment has challenged us all personally, but in the healthcare industry the challenges have become overwhelming. Putting a practice into place to keep your office up to date and able to help patient volume over the coming weeks and months is critical to keeping your practice afloat.

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