The Center for Connected Health Policy (CCHP) has released a new updated telehealth billing guide as a follow up to its 2020 billing guide to provide a helpful tool for healthcare entities trying to navigate the complexities of billing for telehealth and virtually delivered services. Policy changes during the COVID-19 Public Health Emergency (PHE) have only made telehealth billing rules more nuanced. The updated billing guide addresses whether or not there is reimbursement for telehealth both generally and/or during the PHE, as well as how to correctly bill for a telehealth encounter, which is one of the most common policy questions CCHP receives as the National Telehealth Policy Resource Center (NTRC – P). Further complicating the billing process is the need to understand whether current rules are only applicable during the pandemic as well as the fact that payer policies continue to vary from payer to payer. For example, policies that apply to a Medicare beneficiary remain different than those that apply to a state Medicaid enrollee or to patients that have private insurance.
Payment is not guaranteed for any type of visit, even during the temporary PHE flexibilities, whether due to frequency limitations, diagnosis code used, or the specifics of when and what the payer will cover. This guide provides a starting point on how to bill a telehealth encounter for eligible practitioners in a practice or facility, including:
• Applicable requirements during 2021
• Requirements only during the PHE
• Clarifications related to what may occur after then PHE ends
The focus of this billing guide is primarily on fee-for-service Medicare and provides an example of one state Medicaid program, California. Most of the descriptions and definitions used throughout the report are from the Centers for Medicare and Medicaid Services (CMS). The guide takes the reader through:
• Medicare rules for originating and distant sites,
• PHE exceptions,
• Application of the appropriate Place of Service code, modifiers and revenue codes.
In addition, the updated 2021 billing guide highlights:
• California Medicaid (Medi-Cal) policy in call out boxes including the program’s definition of an originating and distant site as well as synchronous and asynchronous store-and-forward telecommunications systems.
• Billing basics for CMS’ communication technology-based services (CTBS), including remote evaluations and virtual check-ins, remote physiologic monitoring, electronic interprofessional consultations, and online digital evaluation services.
• Service codes for principal care management, chronic care management and transitional care management
• Various billing tips to keep in mind
At the end of the guide, eight patient examples are provided that highlight common scenarios that would utilize the coding procedures outlined throughout the billing guide. The examples present a patient scenario (for example, a synchronous telehealth visit with an established patient who is covered by Medicare), and then shows how a biller would code the visit that occurred within the billing form.
Download Guide by clicking here.
Emergency Broadband Benefit Program Updates
On February 25th 2021, the Federal Communications Commission (FCC) adopted, through a unanimous vote, the establishment of the Emergency Broadband Benefit Program, which is a $3.2 billion federally funded effort to increase internet accessibility and affordability to underserved communities throughout the country.
The program seeks to assist households struggling during the pandemic to virtually connect to vital services, such as healthcare and education services, through monthly discounts for broadband service – up to $50 a month, or $75 a month for those on Tribal lands. Eligible households will also be provided discounts on computers or tablets of up to $100. Eligibility is based upon participation in existing broadband provider low-income or pandemic relief programs, Lifeline subscribers, Pell grant recipients, households with children receiving free and reduced-price school meals, and those that have lost employment and income over the past year.
The FCC Acting Chairwoman Jessica Rosenworcel announced that the program should be open by late April of this year. For more details, access the FCC press release.
Source Center of Connected Health Policy
