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Grasping the new normal -- policy enables telehealth usage to continue to expand

Posted: April 02, 2020

Navigating COVID-19 as a nation continues to be a daily struggle, but over the last few weeks, we have embraced several positive changes in regards to telehealth and access. With President Trump’s leadership and support of appropriate funding, the Centers for Medicare and Medicaid Services (CMS) has expanded access to services in regards to Medicare specifically.

The implementation of policy changes is currently temporary under the 1135 waiver authority and President Trump’s Supplemental Appropriations Act. The 1135 waiver promotes Medicare to pay for hospital, office and other visits provided via telehealth. A key component is that coverage is also inclusive of the patient’s residence. Providers included in this plan include physicians, psychologists, nurse practitioners, and social workers. The waiver does require that practitioners already have an established patient relationship, but the U.S. Department of Health and Human Services (HHS) also notes that they will not conduct audits of claims submitted during the COVID-19 pandemic.

CMS wants to ensure that patients designated as high-risk of complications from COVID-19 have access to benefits that keep their health the top priority while also preventing the continued spread of the aggressive novel virus. Under this telehealth reimbursement umbrella, routine care is essential to keep the vulnerable geriatric patients in their homes while still maintaining comprehensive care.

Beneficiaries will be able to receive three types of telehealth visits.

  1. Medicare Telehealth Visits - interactive audio and video communication with real-time interaction between the practitioner and the patient. This has the same reimbursement as a traditional face-to-face visit and is classified as such. Flexibility will be granted by the U.S. Department of Health and Human Services (HHS) in regards to coinsurance and deductibles which would typically apply to such services.
  2. Virtual Check-In - a much more broad range of communication including remote evaluation of patient-submitted images or video, and brief telehealth communication for patient management. Patients have to be established with the provider and provider billing prior to submission.
  3. E-Visits - these visits also require a provider-patient established relationship and require the patient to initiate the virtual visit. Practitioners may reach out to patients in regard to the availability of services prior to the patient’s inquiry. All communication is via patient portals and coinsurance and deductible would apply to such services. Appropriate CPT codes include 99421-99423 and HCPCS codes G2061-G206.

Telehealth enables medical practices to continue to offer services to their patients despite the COVID-19 public health emergency. Given the current landscape, practices are encouraged to utilize telehealth whenever possible and to reinforce and establish protocols promoting such visits. To continue to mitigate exposure, further expansion of telehealth may be warranted and may be an alternative in the near future. Government supplementation has also facilitated telehealth changes in Indian Health Services (IHS) and the Veterans Administration.

The changes in Medicare are essential, but not to be overlooked. The American Academy of Pediatrics (AAP) also recently issued guidance in regards to telehealth billing. Current Procedural Terminology (CPT) published documents related to telemedicine, which generate public and private payers the ability to cover telehealth services. The AAP helps practitioners navigate and utilize the available outlets for reimbursement.

So many aspects of the American public’s daily lives have changed, including healthcare and how we provide and receive those services. This COVID-19 pandemic has allowed us to utilize services that have been in place for many years but facilitate growth and new functionality in a changing healthcare environment.