List of Covered Telehealth Services during Public Health Emergency effective 3/1/2020: Link

American College of Physicians Telehealth Summary: Link

CMS Telehealth Provider Fact Sheet (3/17/2020): Link

Novitas Billing for Professional Telehealth Services During the Public Health Emergency: Link

Summary of Telemedicine Services:

Will CMS telemedicine reimbursement regulations apply only to COVID-19 related billings/visits, or will providers really be able to use them for AWVs/TCMs/E&Ms for healthy patients?

The recently passed legislation relaxing telehealth requirements is not limited to COVID-19 billings/visits. For the exact reason of limiting exposure and impact on the healthcare system, we would encourage any visit that can be safely and effectively done via telehealth to convert to telehealth during the public health emergency.

Are telephone and telehealth visits the same?

•Telehealth visits require video and audio communication between a patient and a healthcare provider.

•Telephone only (no video) are reimbursable by Medicare as well as many private payers during this public health emergency

  -No modifier is needed for these codes because they are not telehealth – they are audio only telephone.

  -Use your normal Place of Service.  For instance, POS=11 (private practice).

  -Can be used for new or established patients.

•Telephone only visits are reimbursed at a much lower rate than telehealth visits (video and audio).

Novitas Fee Lookup: Link

What does Medicare pay for telehealth today?

Medicare will pay the distant site practitioner (i.e. the one doing the CPT-described service) the facility rate for the service. Facility rates can be found in the physician fee schedule lookup tool. Physician offices should use Modifier 95. Link

Novitas Medicare Physician Fee Schedule: Link

Are Virtual Check-Ins, Online Digital E/M and Telehealth visits reimbursed the same?

•Telehealth visits (audio and video) intended to be similar to a traditional office visit with technology support. Telehealth services are reimbursed like a normal clinic encounter.

Medicare approved Telehealth Services: Link

What if all the services of the CPT code cannot be accomplished?

The law did not contemplate modifications to CPT codes and CMS has yet to issue guidance on implementation. Unless they do so, we assume all requirements are necessary to bill the code. Telehealth normally requires a patient to go to another health care facility where things like BP and weight can be taken. When the originating site is the home, the lack of certain capabilities may prevent certain codes from being performed even though they are on the telehealth list.

Can I use consumer audio/video communication like FaceTime or Skype?

Yes, the HHS Office of Civil Rights (OCR) issued a notice that specifically allows for use of private consumer technologies. However, purpose-built telehealth tools have many features such as billing assistance, consent management, waiting rooms, etc. that are not available in consumer technologies. If you use consumer technology, you need to ensure all state-required mandates are met, including requirements for patient consent The only thing the waiver does is waive enforcement of the privacy and security requirements of the technology itself.

Additional HIPAA Telehealth HHS Information: Link

Is it only available for established patients?

The federal legislation required physicians to have an established relationship with a patient in order to use these new flexibilities, but CMS has said “HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency.”  This means that the “established relationship” federal requirement essentially does not apply in the current environment.  Link

Additional Information:

AAFP Telehealth Toolkit: Link

Information on skilled nursing facility and home health telehealth services: Link