Before COVID-19

Before Covid 19, Medicare would only pay for telemedicine offered in a HPSA (Health Professional Shortage Area), and the patient had to be in one of the following sites:

  • Physicians or practitioner offices
  • Hospitals
  • Critical Access Hospitals (CAH)
  • Rural Health Clinics
  • Federally Qualified Health Centers
  • Hospital-based or CAH-based Renal Dialysis Centers
  • Skilled Nursing Facilities (SNF)
  • Community Mental Health Centers (CMHC)
  • Note: Independent Renal Dialysis Facilities are not eligible originating site

COVID-19 Changes

The Centers for Medicare & Medicaid Services (CMS) has broadened access to Medicare telehealth services so that beneficiaries can receive a wider range of services from their doctors without having to travel to a healthcare facility. The expansion is made possible on a temporary and emergency basis under the 1135 waiver authority and Coronavirus Preparedness and Response Supplemental Appropriations Act1

  • Doctors and practitioners can use telehealth for the face-to-face encounter to qualify for Medicare home health care.
  • Medicare can pay for office visits furnished via telehealth across the country and including in patient’s place of residence starting 3/6/20.
  • Doctors, nurse practitioners, clinical psychologists, and licensed clinical social workers can provide telehealth to their patients.
  • Services that can now be provided include evaluation and management (E&M) visits, mental health counseling, and preventative health screenings. These visits are considered the same as in-person visits and are paid at the same rate as regular, in-person visits.
  • The HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive coinsurance or deductibles for telehealth visits paid by Medicare.
  • To the extent that the 1135 waiver requires an established relationship, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this emergency.
  • Covered healthcare providers will not be subject to penalties for violations of the HIPAA Privacy, Security, and Breach Notification rules that occur in the good faith provision of telehealth during the COVID-19 nationwide public health emergency (Source: FAQs on telehealth and HIPAA during the COVID-19 nationwide public health emergency, www.hhs.gov/sites/default/files/telehealth-faqs-508.pdf)
Codes and Reimbursement
Service Code Description Reimbursement
Telehealth visits – a visit with a provider that uses a telecommunications system 99201-99215 Office or other outpatient visits These visits are considered the same as in-person visits and are paid at the same rate as regular, in-person visits.
1Virtual Check in – a 5-10 minute check in with practitioner via telephone or other telecommunications device to determine whether an office visit or other service is needed. HCPCS code G2012 Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.
HCPCS code G2010 Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment.
E Visits with established patients through an online patient portal (patient initiated) 99421 Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5–10 minutes
99422 Online digital evaluation and management service, for an established patient, for up to 7 days cumulative time during the 7 days; 11– 20 minutes
99423 Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 21 or more minutes.
News/Press Releases:

Secretary Azar Announces Historic Expansion of Telehealth Access to Combat COVID-19
Definitions:
  • Telehealth – the use of electronic information and telecommunications technologies to support and promote long-distance clinical health care, patient and professional health related education, and public health and health administration. Technologies include videoconferencing, the internet, store and forward imaging, streaming media, and landline and wireless communication
  • Remote patient monitoring
  • Asynchronous/Store and forward
  • Sites
    • Originating Site – where the patient is located
    • Distant Site – where the healthcare provider is located
  • • HPSA (Health Professional Shortage Area) can be determined through this link: https://data.hrsa.gov/tools/shortage-area/hpsa-find

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