p4 pitfalls of telemedicine - hcca official site · b. no, but we are working on getting a...
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Navigating the Compliance Pitfalls of Telemedicine
Presented by
CJ Wolf MD, CHC, CPC
Healthicity | Senior Compliance Executive
Jay McVean CPC, OHCC UTHealth | Director Medical School Billing Compliance
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Poll QuestionDo you currently have an active telemedicine program at your organization/physician practice?
A. Yes, our program is live and actively seeing patients.
B. No, but we are working on getting a telemedicine program up and running.
C. No, haven’t even started down the telemedicine road.
D. Yes, but struggling to get off the launching pad.
Poll QuestionWhat Type of Telemedicine program best fits your patient/ practice needs?
A. Primary Care
B. Specialty Care
C. Combination of both
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OIG Work Plan
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OIG Work Plan Audit Results‐‐MedicarePublished April 2018
31 of 100 claims did not meet requirements. Specifically:
• 24 claims were unallowable because the beneficiaries received services at nonrural originating sites,
• 7 claims were billed by ineligible institutional providers,
• 3 claims were for services provided to beneficiaries at unauthorized originating sites,
• 2 claims were for services provided by an unallowable means of communication,
• 1 claim was for a noncovered service, and
• 1 claim was for services provided by a physician located outside the United States.
OIG, CMS, DOJ are not the only enforcersJuly 2019 issue of Compliance Today
“Telemedicine: Understanding the FDA's role in recent regulatory and enforcement actions”
By Serra J. Schlanger, Esq. and Rachael E. Hunt, Esq.
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Poll QuestionWhat aspect of Telemedicine do you thinks brings the greatest compliance risk?
A. Clinician licensure/eligibility
B. Distant site issues/Origination site issues
C. Medical record documentation
D. Billing and coding regulations
E. HIPAA/PHI Security issues
Every state but Connecticut and Massachusetts has made substantive legal changes to how telehealth is delivered in the past year, with some taking specific actions to better define the path of mental health‐focused treatment.
https://www.mobihealthnews.com/content/report‐nearly‐every‐state‐has‐updated‐its‐telehealth‐legislation‐last‐year
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UPDATE!!Thirty‐one states and Congress have passed legislation or regulations pertaining to telehealth this past year (2018). Most of those deal with reimbursement or licensure for providers practicing remote care. A few of the new rule changes offer increased availability for the direct‐to‐patient telemedicine services.
https://simplevisit.com/2018‐telemedicine‐policy‐update/
Getting StartedKnow your book of business!!
◦ Is telemedicine a viable service for your…◦ Practice type?
◦ Patient population?
◦ Location?
◦ Payer mix?
If YES to any or all of these question, then keep moving forward!!
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Steering Committees & Physician InterestIs your organization large enough that a Steering Committee is needed to drive the project?◦ If so, who are your key stakeholders in the project?◦ Physician Leaders
◦ Administrative Leaders
◦ Compliance Leadership
◦ Revenue Cycle Leadership
◦ Information Technology Leadership
Steering Committees & Physician InterestIf you are an individual provider or small group practice, are you or your providers onboard with the idea of practicing medicine online?
◦ What percentage of your current patient population could or would benefit from telemedicine services?
◦ Advantages vs. Disadvantages?
◦ Will telemedicine improve or detract from my current level of patient care?
◦ How will telemedicine impact my current clinic schedule?
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Telemedicine Delivery PlatformFull IT Security vetting process◦ Is it HIPAA compliant?
◦ Is it secure?
◦ SKYPE
◦ FaceTime
Many Telemedicine solution vendors◦ Find the one that fits your organizations needs.
Poll QuestionWhat specialty within your organization would benefit most from a telemedicine practice?
A. Family Medicine
B. Pediatrics
C. Neurology
D. Internal Medicine
E. Other
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Getting StartedIdentify Service Lines/Clinics that would benefit from telemedicine services most?◦ Pediatric
◦ Neurology
◦ Family Medicine
◦ Orthopedics
◦ Psychiatry
Getting StartedIdentify types of services you wish to offer.
◦ Established patient clinic visits
◦ Outpatient Consults
◦ Inpatient Consults
◦ Post‐op encounters
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Building a Telemedicine PracticeHow do you notify patients about your new Telemedicine service?
◦ Identify them during an office visit◦ Based on this clinical needs, if they are a good candidate for future telemedicine visits, offer that as a alternative moving forward
◦ Pamphlets or brochures
◦ Email marketing – but be careful!!!
◦ Consult with your Telemedicine vendor about other marketing options
Scheduling Telemedicine VisitsWhen and where do you put these visits on your providers schedule?◦ This could vary based on several factors◦ Your organizations telemedicine model.
◦ Urgent Care – 24/7 staffing
◦ Specialty service model
◦ Do you schedule telemedicine visits on a provider’s clinic days??◦ In between office visits?
◦ Half a day telemedicine…Half a day in patient visits?
◦ Providers only preform telemedicine visits after the clinic day is complete?
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Telemedicine DocumentationDocumentation will look very much like and E/M visit preformed in the office/facility.◦ Select a level of service based on the three key components (History, Physical Exam, Medical Decision Making), or
◦ Select a level of service based on Time.
Poll QuestionDoes your organization bill as the “Origination” site or as the “Distant” site?
A. Origination site
B. Distant site
C. Both
D. I have no clue what this guy is talking about!
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Billing For TelemedicineWhat is the “Originating” site?◦ An originating site is the location where a Medicare beneficiary gets physician or practitioner medical services through a telecommunications system. ◦ …where the patient is located!
◦ Physician and practitioner offices
◦ Hospitals
◦ Critical Access Hospitals (CAHs)
◦ Rural Health Clinics
◦ Federally Qualified Health Centers
◦ Hospital‐based or CAH‐based Renal Dialysis Centers (including satellites)
Originating SitesWhat are eligible Originating Sites?
◦ Physician and practitioner offices
◦ Hospitals
◦ Critical Access Hospitals (CAHs)
◦ Rural Health Clinics
◦ Federally Qualified Health Centers
◦ Hospital‐based or CAH‐based Renal Dialysis Centers (including satellites)
◦ Skilled Nursing Facilities (SNFs)
◦ Community Mental Health Centers (CMHCs)
◦ Renal Dialysis Facilities
◦ Homes of beneficiaries with End‐Stage Renal Disease (ESRD) getting home dialysis
◦ Mobile Stroke Units
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Distant SitesDistant site is the location of the provider who is performing/billing for the telemedicine visit. ◦ Physicians◦ Nurse practitioners (NPs)◦ Physician assistants (PAs)◦ Nurse‐midwives◦ Clinical nurse specialists (CNSs)◦ Certified registered nurse anesthetists◦ Registered dietitians or nutrition professional◦ Clinical psychologists (CPs) and clinical social workers (CSWs)◦ CPs and CSWs cannot bill Medicare for psychiatric diagnostic interview examinations with medical services or medical evaluation and management services. They cannot bill or get paid for Current Procedural Terminology (CPT) codes 90792, 90833, 90836, and 90838
CMS Says…
You must use an interactive audio and video telecommunications system that permits real‐timecommunication between you at the distant site, and the beneficiary at the originating site.
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Claim Submission – Distant Site ProviderSubmit telehealth services claims, using Place of Service (POS) 02‐Telehealth, to indicate you furnished the billed service as a professional telehealth service from a distant site. ◦ As of January 1, 2018, distant site practitioners billing telehealth services under the CAH Optional Payment Method II must submit institutional claims using the GT modifier.
◦ Some payers may ask for a GQ modifier.
◦ Some payers may not want a modifier at all.
Code the service the practitioner provided with the appropriate CPT or HCPCS code that describes the services.
“The Reassignment Riddle: Billing Medicare for Distant Site Services”
July 2019 issue of Compliance Today
Article by Sean T. Sullivan, Esq.
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Claim Submission – Originating Site
HCPCS Code Q3014 describes the Medicare telehealth originating sites facility fee.
2019 CMS Rule ChangesBrief Communication Technology‐based Service, e.g. Virtual Check‐in (HCPCS code G2012): Check‐in services used to evaluate whether or not an office visit or other service is necessary. The modalities will include audio‐only real‐time telephone interaction in addition to synchronous, two‐way audio interaction that are enhanced with video or other kinds of data transmission. CMS will pay approximately $14 for this service (unless it is the result of a previous appointment or leads to a face‐to‐face appointment). CMS believes the check‐ins will mitigate the need for potentially unnecessary office visits.
Remote Evaluation of Pre‐Recorded Patient Information (HCPCS code G2010): CMS finalized the creation of a specific new code to describe remote professional evaluation of patient‐transmitted information conducted via pre‐recorded “store‐and‐forward” video or image technology. These services would not be subject to the Medicare telehealth restrictions because they could not substitute for an in‐person service currently separately payable under the PFS.
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2019 CMS Rule ChangesInterprofessional Internet Consultation (CPT codes 99452, 99451, 99446, 99447, 99448, and 99449): These codes would cover interprofessional consultations performed via communications technology such as telephone or Internet. This would support a team‐based approach to care that are often facilitated by electronic medical record technology.
For both the Virtual Check‐In and the Remote Evaluation for Pre‐Recorded Patient Information, CMS made very clear that the codes will only be available to practitioners who furnish E/M services which would exclude clinical staff such as RNs and physical therapists and that copayments will continue to apply.
◦ FQHC or RHC are not eligible to bill for the interprofessional internet consultation codes.
https://www.telehealthresourcecenter.org/big‐changes‐in‐2019‐for‐medicare‐telehealth‐policy/
Begins 1/1/2020
https://www.cms.gov/newsroom/press‐releases/cms‐finalizes‐policies‐bring‐innovative‐telehealth‐benefit‐medicare‐advantage
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ResourcesCMS – Telehealth Services Manual◦ https://www.cms.gov/Outreach‐and‐Education/Medicare‐learning‐network‐MLN/MLNProducts/downloads/TelehealthSrvcsfctsht.pdf
Cybersecurityhttps://www.nccoe.nist.gov/sites/default/files/library/project‐descriptions/hit‐th‐project‐description‐final.pdf
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Cybersecurityhttps://www.nccoe.nist.gov/sites/default/files/library/sp1800/hit‐wip‐nist‐sp1800‐8.pdf
Cybersecurityhttps://www.nccoe.nist.gov/sites/default/files/library/sp1800/hit‐ehr‐nist‐sp1800‐1.pdf
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HRSA‐‐https://www.hrsa.gov/rural‐health/telehealth/index.html
HRSA‐‐https://www.hrsa.gov/rural‐health/telehealth/index.html
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https://www.telehealthresourcecenter.org/
https://www.healthicity.com/resources/compliance‐conversations‐podcast‐episode‐thirty?hsCtaTracking=5d124661‐9328‐4995‐aa78‐11b81fcf42df%7C4836f486‐17ca‐4ff6‐89e1‐7e8f02bf7770
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