Ryan Spaulding, PhDVice Chancellor, Community EngagementActing Director, Center for Telemedicine & TelehealthAssociate Professor, Biostatistics and Data Science

Telemedicine - patient-provider, real-time video consultationsTelephone – patient-provider, real-time audio consultationsTelehealth – store-and-forward, wearables, asynchronous remote monitoring

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Video vs. Telephone• Video, in most cases, required to be considered a telemedicine visit

• Telemedicine visits reimbursed by Medicare, Medicaid and private payers

• Telephone consults not typically reimbursed except Medicare Virtual Check-Ins

• Exception is if telephone has video capabilities and video is utilized, i.e. smartphone

•Additional exceptions in Kansas with COVID

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• Pertains to the type of video platform used• Action will waive potential penalties for HIPAA violations if using

everyday communication technologies.• Common apps like Facetime, Skype, Google Hangouts video, Facebook

Messenger video may be used• Apps Facebook Live, Twitch, TikTok should NOT be used• Key distinctions appears to be whether app is intended for an audience

or entertainment vs. individual or small group meetings• Even with these apps, all security settings should be turned on• Must be used in good faith• Should verbally inform patients that the apps may “potentially

introduce privacy risks” • For any consults, not just COVID-19 related

https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html

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The prescription is issued for a legitimate medical purpose by a practitioner acting in the usual course of his/her professional practice;

The telemedicine communication is conducted using an audio-visual, real-time, two-way interactive communication system; and

The practitioner is acting in accordance with applicable Federal and State laws.

https://www.deadiversion.usdoj.gov/coronavirus.html

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https://www.washingtonexaminer.com/news/trump-administration-will-allow-doctors-to-practice-across-state-lines-to-address-pandemic

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• Effective March 23rd

• Some mental health, SUD, SBIRT, autism and E/M codes now eligible for telemedicine

• Can be provided by video or telephone except autism, no phone and provided to home as originating site

• Nursing facilities can serve as originating sites using Q3014 code

• When originating site is home, POS is 12 “home,” not telemedicine

• Services temporarily allowed by non-network providers including physicians, mid-levels and non-physician practitioners

• KMAP General Bulletin 20046

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Service VideoReimburse?

PhoneReimburse

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Pt. Home? Payers

Medicare typical telemedconsult

Yes No Yes CMS

Medicare Check Ins Yes Yes Yes CMS

Kansas typical telemedconsult (99201-99203, 99211-99213)

Yes Yes Yes KanCare

Kansas SUD Yes Yes Yes Block Grants, KanCare

Kansas Mental Health codes, limited

Yes Yes Yes KanCare

Kansas SBIRT Yes Yes Yes KanCare

Kansas autism codes Yes No Yes KanCare

Kansas SB 123 Yes No Yes General Fund

Kansas HCBS Waivers Yes Yes Yes KanCare

Kansas PCSP Yes Yes Yes KanCare

Home Health Care Setting

Send link to patient Send link to originating site contact, often a nurse “tele-presenter”

Assist patient with audio/video Assist tele-presenter as needed

Ask patient if alone or assess room with video

Ensure room is exam room or private

If using atypical video app, inform patient of potential for security risk

Inform both tele-presenter and patient

Patient self-report symptoms and temperature if needed

Tele-presenter can take vitals and report to you

Conduct consultation as you normally would

Conduct consultation as you normally would

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• Place of Service is 02 for CMS• POS in KS is 12 or Q3014• Document that visit occurred via telehealth• Patient consented to telehealth visit• Where patient and provider were located• Whether any technical problems occurred and how

affected the consult• Examination or vital signs by proxy if done from

originating site or no examination/self-reported if done in home

• May want to document that this was during the COVID-19 outbreak

• For Medicare patients, video is suggested, HIPAA compliant or other common video apps, home

• Kansas KanCare patients, phone or video, home, many traditional outpatient, mental health and SUD services

• Private payers’ guidance not provided but often follow lead of CMS and state policies

• In all cases, typical co-pays and deductibles still apply• Providers at home not clear but has been done

•https://www.cms.gov/files/document/03052020-medicare-covid-19-fact-sheet.pdfhttps://www.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf

•https://www.cchpca.org/resources/covid-19-telehealth-coverage-policies

•https://www.telehealthresourcecenter.org/wp-content/uploads/2020/03/Telehealth-and-COVID-19-FINAL.pdfhttps://www.youtube.com/watch?v HtMYM9zdqM0&feature youtu.be&list PLJ3YvVX2HpzVXTnfXMUG_dd6RcGWd4Pt7

•https://www.hhs.gov/about/news/2020/03/17/ocr-announces-notification-of-enforcement-discretion-for-telehealth-remote-communications-during-the-covid-19.html

Ryan Spaulding913.588.2251

rspaulding@kumc.edu