Centers for Medicare & Medicaid Services (CMS) held a Special Open Door Forum that was open to the public on April 8, 2020. CMS has been working to address the COVID-19 pandemic through 1) increasing hospital capacity, 2) rapid expansion of the healthcare workforce, 3) relaxing health care administrative requirements, and promoting the use of telehealth, which this call was focused on. The call provided an opportunity for health care providers to ask specific questions and express concerns about telehealth and Medicare reimbursement.
Emily Yoder, an analyst in the Division of Practitioner Services (DPS) in the CMS Center for Medicare, provided a summary of the recent changes that have taken place for telehealth in response to the COVID-19 pandemic through blanket waivers and recent legislation, including the Coronavirus Aid, Relief, and Economic Support Act (CARES Act). Previously, Medicare provided coverage for telehealth services only if the “originating site” was in a rural area and the patient was located in a medical facility. Now, in response to COVID-19, Medicare coverage for telehealth services is no longer restricted to rural areas and the patient may be located in their home when receiving services.
In the Interim Final Rule (IFR), CMS expanded the list of telehealth services eligible for reimbursement, including emergency department visits, observation day management, critical care, home visits, intensive care, and radiation treatment management. The list of eligible distant site providers also expanded, including the addition of FQHCs and RHCs. For billing, rather than using Place of Service (POS) code 2, practitioners should use modifier 95 and the POS code that would be used if the service was provided in person. The “distant site” should bill the same CPT/HCPCS code they would bill if the service was provided in person. The “originating site” should include HCPCS code Q3014 for facility fee claims. Medicare will pay the same amount for telehealth services as it would if the services were provided in person.
In the Q&A session, several health care providers expressed challenges with the inability to use audio only telephone to provide care if needed. Medicare will reimburse for telehealth services provided through an interactive telecommunications system, meaning audio and video equipment permitting two-way, real-time interactive communication between the patient and distant site physician or practitioner. CMS has provided specific codes for services that may be provided via audio only telephone (CPT codes 98966 -98968 and 99441-99443) but this list of services is limited. Several providers on the call noted that they struggle with patients who do not have access to interactive audio and video technology or do not know how to use such technology, especially the elderly Medicare population. Providers continue to provide services via telephone for patients who have no other option and are taking a loss as they are not allowed to bill. Yoder acknowledged that CMS had received extensive feedback along these lines and is currently considering how to use its waiver authority granted under the CARES Act to potentially provide additional coverage for audio only telephone services.
Another issue that came up during Q&A is that the list of eligible providers expanded in the CARES Act does not include physical therapists, occupational therapists, and speech therapists so that these providers cannot receive Medicare reimbursement for telehealth services. Yoder also acknowledged that this issue has come up repeatedly and is another area that CMS is considering using its waiver authority to potentially address.
Finally, several providers also questioned how to bill for the factual scenario where a practitioner and a patient are located at the same facility and they are communicating via phone from separate units/rooms to avoid contact to reduce the spread of COVID-19. If the professional and patient are at the same site, Yoder advised that these services may be billed as in-person visits rather than as telehealth services since the provider is available on site.
CMS is accepting questions via firstname.lastname@example.org and will take the questions into consideration in determining how to use its waiver authority to provide further access to telehealth moving forward. The recordings of this call along with transcripts may be accessed on the following link: https://www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/PodcastAndTranscripts.