MedPage Today: Telehealth expansion opens the door to reimbursement troubles

by: Julia Kyles, CPC Apr 17, 2020

CMS and private payers have knocked down barriers for telehealth and telemedicine services during the COVID-19 public health emergency (PHE). But a MedPage Today article reveals that barriers to payment remain, and the steady flow of changes to coding and billing guidance is a major hurdle.

For example, the article mentions the place of service guidelines for doctors who provide telehealth services to patients who are not at a designated distant site.

CMS also directed providers to designate a place of service when billing, initially asking them to enter a specific code.

That is, CMS told doctors to append telehealth place of service (POS) 02 to their claims. Doing so triggered a 30% pay cut: Claims with POS 02 were reimbursed at 70%, one doctor said. The article notes that the problem was solved when CMS changed its guidance and instructed practices to select the place of service code based on the location the face-to-face visit would have occurred. However, practices that didn’t get the update may have resigned themselves to lower payments.

It’s no surprise that practices are struggling to keep up with the rules for telehealth and other communications-based services in the midst of a pandemic. When we scheduled an April 21 webinar about CMS’ temporary telehealth expansion and the related compliance waivers we thought CMS might issue one or two policy revisions.

We were slightly off in our assumptions. By our count CMS has issued 10 changes to its telehealth and telemedicine policies since we scheduled the webinar on March 25.

Fortunately, the webinar will be presented by Betsy Nicoletti, CPC, president of Medical Practice Consulting in Northampton, Mass. She followed the twists and turns of CMS’ guidance, its updates to the guidance and its revisions to the updates to the guidance and captured them all in her presentation. Here’s a list of topics she had to track:

Documentation for office E/M services.
Coverage of telephone E/M encounters.
Definition of communications-based services.
New designated telehealth codes.
HIPAA compliance.
Modifier 95.
Place of service codes.
Direct supervision guidelines.
Modifier CS.
Revised information for modifier CS.

It’s not too late to sign up to get caught up, have a chance to ask questions and earn 1 AAPC CEU. Register for Telehealth During the COVID-19 Crisis: Protect Patients, Maintain Continuity of Care, and Sustain Revenue, April 21, 1-2 p.m., ET.

Each registration includes on-demand access to the slides and recording. 1 AAPC CEU is available for people who listen to the recording and pass a quiz.

Blog Tags: claims processing, CMS, COVID-19, telehealth

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