COVID-19 Quick Reference Guide: Telehealth for Indiana Medicare Providers

COVID-19: Telehealth for Indiana's Medicare Providers

In an effort to ensure access to healthcare during these uncertain times, CMS broadened Medicare’s telehealth coverage so that patients can see a provider without leaving their homes. Although this expansion of benefits is temporary, CMS urges both providers and patient to take advantage of the telehealth as means to reduce potential exposure to the Coronavirus for both the patient and the healthcare facility.

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1135 Waiver

Through this waiver, CMS will pay for healthcare services provided to patient via telehealth. The waiver includes services provided by physicians, nurse practitioners, clinical psychologists, and licensed clinical social workers. Medicare beneficiaries will be able to receive a set number of virtual visits via telehealth including office visits, mental health counseling, and preventative health screenings. CMS has defined three types of telehealth visits that are eligible for reimbursement: Medicare telehealth visits, Virtual Check-ins, and E-visits.

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Types of Visits

• Medicare Telehealth Visit

  • Can take the place of a face to face office visit
  • Provider must use an interactive platform that includes audio and visual capabilities to assess and treat the patient at home
  • Although Medicare and coinsurance deductibles would normally apply to these visits, there is flexibility to reduce or waive cost sharing for telehealth visits paid by federal programs
  • No established provider/patient relationship is required

  Virtual Check-ins

  • Brief communication of the patient and provider using telephone, audio/video, secure text messaging, email, or use of a patient portal
  • Patient and provider relationship must be established prior to the virtual check-in
  • Must not be related to a medical visit within the previous 7 days and must not result in a medical visit within the next 24 hours or next available appointment
  • Available in all areas, not limited to rural

E-visits

• • Patient initiated online visit with the provider using a patient portal
  • Must have an established relationship with the provider
  • Patient must initiate the initial inquiry and communication with the provider may occur over a 7-day period
  • The patient must verbally consent to receive virtual check-in services
  • Medicare co-insurance and deductibles apply to this service

 

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Medicare Provider Telehealth Billing Information

Services can be provided via Audio & Video, Audio Only or Online-Only

Audio & Video

• Use E&M Codes 99201-99215, and coding can be based on Time Spent or Medical-Decision-Making (MDM)

TIME Time now includes all time associated with the visit on the same day, including non-face-to-face time. Counseling does not have to be the main focus of the visit. 99201 17 min total 99202 22 min total 99203 29 min total 99204 45 min total 99205 67 min total 99212 16 min total 99213 23 min total 99214 40 min total 99215 55 min total Use Place of Service (POS) 11 Use Modifier 95

MDM No history and/or exam requirements MDM should be based on current guidance, so continue using 1995/1997 E&M guidelines

 

Audio Only   

For services provided by physicians and advanced practitioners:

99441	5-10 min of medical discussion
99442	11-20 min of medical discussion
99443	21+ min of medical discussion
G2012	5-10 min Virtual Check-In
G0071	5-10 min Virtual Check-In by FQHC

 

For services provided by qualified non-physician professionals not eligible to bill E&M codes:

98966	5-10 min of medical discussion
98967	11-20 min of medical discussion
98968	21+ min of medical discussion

• Use Place of Service (POS) 11
• No Modifiers
• Must be no related E&M used in previous 7 days, and no subsequent services planned in the next 24 hours

 

Online only   

 For services provided by physicians and advanced practitioners:

99421	5-10 min
99422	11-20 min
99423	21+ min
G2010	Review of captured video and/or image
G0071	5-10 min virtual check-in by FQHC

 

Qualified non-physician professionals not eligible to bill E&M codes:

G2061	5-10 min
G2062	11-20 min
G2063	21+ min

• Time based on up to 7 days of cumulative time 

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HIPAA and Telehealth Services

Effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency. Healthcare providers should not use public-facing communication applications such as Facebook Live, TikTok, Twitch and similar applications.

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Opioid Prescribing

Per Indiana Governor Holcomb’s Executive Order 20-13, which allows a prescriber who is also a DEA-registered practitioner to issue prescriptions for all Schedule II-V controlled substances for patients for whom they have not conducted an in-person medical evaluation, provided:

• The prescription is issued for a legitimate medical purpose by a prescriber acting in the usual course of their professional practice; 
• The telecommunication is conducted using an audio-visual, real-time, two-way interactive communication system; and
• All other applicable state and federal laws are followed.

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Additional COVID-19 Resources

CMS information for Medicare healthcare providers:

FACT SHEET:  Medicare Telemedicine for Healthcare Providers  03/17/2020

FAQs:  COVID-19 Frequently Asked Questions   03/17/2020 Release

FAQs:  COVID-19 Frequently Asked Questions (Additional)   03/23/2020 Release

MLN:  Medicare Fee-for-Service Response to COVID-19   03/20/2020

NEWSROOM:  Sweeping Regulatory Changes to Help US Healthcare System Address COVID-19 Patient Surge  03/30/2020

Indiana-specific information:

Indiana State Dept. of Health (ISDH) COVID-19 Professional Resources

Indiana Board of Pharmacy COVID-19 Actions & Controlled Substances

Upper-Midwest Telehealth Resource Center (UMTRC) Indiana COVID-19 Resources

Indiana State Medical Association (ISMA) COVID-19 Resources

Other:

AAFP:  Using Telehealth to Care for Patients During COVID-19

AMA:  Quick Guide to Telemedicine in Practice

AMA:  Special Coding Advice During COVID-19 Public Health Emergency

AMA:  Telehealth Implementation Playbook

Indiana State Medical Association (ISMA): COVID-19 Telemedicine Billing Decision Tree

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References

Centers for Medicare and Medicaid Services (CMS), Interim Final Rule, Policy & Regulatory Revisions in Response to the COVID-19 Public Health Emergency.  April 6, 2020, and

Indiana State Medical Association (ISMA) and MedLucid Solutions.  Billing and Coding for Telehealth Under COVID-19, Part 1.  April 8, 2020.

CMS-1715-F, Revisions to Payment Policies under the Medicare Physician Fee Schedule, Quality Payment Program and Other Revisions to Part B for CY 2020,