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9.25.19
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2019 Changes To Telehealth Reimbursement

Adam Kenney

Earlier this year the Centers for Medicare and Medicaid Services (CMS) made the biggest change to telehealth policy in decades. In one abrupt, little-advertised bulletin, it announced that it would begin paying for five entirely new “Category 2” telehealth services on January 1, 2019. In that instant, tens of millions of Medicare beneficiaries became eligible for new remote services. However, nine months later very few of their physicians know about the change, and even fewer have the tools to offer or bill for these services.Most physicians and practice administrators still think of telehealth as largely unfunded. This is understandable because until 2019 Medicare still only reimbursed provider-to-patient video visits, and only for patients located in rural areas, and only when the patient was physically located at a medical facility such as a clinic or hospital. In effect, CMS only used telehealth to supplement specialist staffing at medical facilities in rural areas. It didn’t want to introduce competition against the traditional office visit.So until this year, telehealth was progressing mainly in the private sector. Because of successful direct-to-consumer telehealth companies, we associate telehealth with several major benefits: convenience and time savings for patients, increased access to care, work-life balance for physicians, and lower costs. CMS took a big step towards these additional benefits in the public sector with its new Category 2 telehealth funding.

Category 2 Telehealth Services and Charge Codes

Here are the new Category 2 services that can be billed today for Medicare patients:

Interprofessional Internet Consultation

This is a physician-to-physician service billed by a consulting specialist. The specialist uses phone or video to give treatment guidance to the referring physician, along with a written report. The specialist never has any contact with the patient. The reimbursement is small, but many specialists already offer phone advice to other physicians without always seeing the patient. Now they can be reimbursed for these calls - it removes a perverse financial incentive for them to always do an in-person consult when that might not be necessary and could be an extra expense and inconvenience for the patient.

Interprofessional Written Internet Consultation

This is similar to the Interprofessional Internet Consultation above, but removes the voice or video requirement. The specialist’s treatment guidance is purely written in this scenario.

Interprofessional Referral Services

This pays the referring physician (typically a primary care physician, family medicine doctor, or hospitalist) for their end of the interprofessional internet consultation described above. The billing is based on time spent preparing materials, reviewing documentation, and speaking with the specialist. It’s nice that both parties can now get reimbursed for something that they were already doing in many cases.

Remote Evaluation of Pre-Recorded Patient Information

Consumer wearable medical devices got ahead of reimbursement models, leaving physicians to wonder “how am I going to get reimbursed for interpreting this flood of patient-generated data?” Apparently by billing G2010. When a physician gets a medical recording or image directly from a patient, this code pays them to send their interpretation back. No voice or video involved, just text chat. The reimbursement is low, but then again, it’s a simple transaction and it could be high-volume with the right marketing and tools.

Virtual Check-in

This code pays a physician to talk with an established patient for 5-10 minutes, as long as it’s unrelated to any scheduled in-office visits from the past 7 days and doesn’t lead to an immediate office visit or procedure. Typically this would be used after the patient calls the practice with a complaint or question, and the call gets escalated to a physician. It can be proactive on the part of the practice as well. Many practices traditionally provide this service for free for their established patients - now there’s reimbursement available.

How to Get Reimbursed for Category 2 Telehealth Services

If you’re already meeting the requirements to bill for one of these services, then the remaining challenge is charge capture. Because of the time requirements and the coding complexity, it’s prohibitively time-consuming to capture the billing charges for these services unless you can do the charge capture in the same clinical communication software where the service itself took place.In order to fully capitalize on these codes, health care organizations should invest in integrated charge capture and clinical communication software. This software can be used for interprofessional and provider-patient text chat, voice, and video. The same software then can guide the physician to bill the appropriate Category 2 charge code based on the type of service (provider-provider or provider-patient), type of communication (text, phone, or video), and the duration of the call. It has to be mobile because who is in front of a computer every time they talk on the phone? And it has to be easy and integrated so that the time spent on charge capture doesn’t exceed the time spent on the actual encounter!Why miss out on telehealth reimbursement? Contact pMD to find out how our easy-to-use, integrated charge capture and clinical communication software can streamline your telehealth services!

Further Reading

https://www.aappublications.org/news/2019/01/04/coding010419https://practice.asco.org/sites/default/files/drupalfiles/2018-12/Final-Rule-2019-Resource-FINAL-12-5-18.pdf

https://acpinternist.org/archives/2014/01/coding.html

To find out more about pMD's suite of products, which includes our charge capture and MIPS registry, billing services, telehealth, secure messaging, and care navigation software and services, please contact pMD.

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