The Centers for Medicare and Medicaid services has broadened access to Medicare telehealth services so beneficiaries can access a wider range of physician services without having to go to a healthcare facility. Commercial plans have followed suit. The benefit under the waiver 1135 and the Coronavirus Preparedness and Response Supplemental Appropriations Act while temporary, expands the use of technology to help patients who need routine care and vulnerable beneficiaries in their homes.
Here is a quick guide of how to set your practice up to provide telehealth services. Basically, there are three types of services:
1. Traditional telehealth, which now has material modifications to make it easy to participate
2. Virtual Check Ins, which are a Medicare service offered over the phone, have been around for a few years
3. E Visits through a patient portal, which also are not new.
Medicare significantly relaxed their requirements to conduct a telehealth visit. Specifically, the patient can now be in his home, he does not have to live in a rural area and you can use a mobile phone video conferencing apps for the visit. HIPPA restrictions have been lessened to allow these modifications. Visits could start as early as March 6, 2020 and will go on indefinitely. Visits can be provided by physicians, mid-levels and others.
You will want to document telehealth visits in your EHR just like you do currently for office visits, so you will need a telehealth place of service 02 and an appointment schedule for that place of service and the providers who will see telehealth patients. You will use E&M codes for the visits and will be reimbursed on the physician fee schedule. You will need to document you received verbal consent from the patient and your documentation needs to support your E&M code choice.
Patients will need to be notified that you are offering telemedicine visits. You may also consider proactively shifting existing office visits to virtual ones. You will need to choose the technology to use. Your medical record vendor may have technology built in. Or consider Facetime, Facebook messenger Video Chat, Skype, Doxy.me etc.
When scheduling these visits, your front desk will need to be sure you have the patients phone number to call and which technology will be used noted. You may choose to have a staff member responsible for getting patients on the call prior to hand off to physician or midlevel conducting the visit.
Commercial carriers have followed Medicare in allowing these waived telehealth visits. You need to check the rules for carriers in your state. While Medicare requires audio and video for their visits, many of the commercial carriers allow these visits to be conducted over the phone. The commercial carriers also typically limit the E&M codes you can use to 99211 through 99213. It is common for wellness visits to not be covered.
All of this needs to be done quickly. Some of the commercial carriers offer these waived services for a month, others for 90 days. It is very likely that this temporary move will be a catalyst for a virtual medical visits in the future. While this is a temporary option now, once we are out of this pandemic, practices will need to consider whether a telemedicine option makes sense for the future.