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COVID-19 VHAN Survey

The Coronavirus Preparedness and Response Supplemental Appropriations Act, as signed into law on March 6, 2020, allows the Department of Health and Human Services (HHS) to waive certain Medicare telehealth payment requirements to allow beneficiaries to receive telehealth services, including at their home.

The rule allows a greater range of services to be provided via telehealth including:

  • ED visits
  • Inpatient care
  • Nursing and home visits
  • Critical care
  • Neonatal and pedi critical care and continuing care
  • Care planning for cognitive impairment and psychological and neuropsychological testing
  • Physical therapy and occupational therapy
  • Radiation treatment management
  • Services performed by social workers, clinical psychologists and speech language pathology.

This full list is available here. These services—described by HCPCS codes and paid under the Physician Fee Schedule—may be provided to patients by professionals regardless of patient location.

Medicare pays separately for other professional services commonly furnished remotely using telecommunications technology, such as physician interpretation of diagnostic tests, care management services and virtual check-ins.

Qualified providers include physicians, nurse practitioners, physician assistants and certified nurse midwives. Other practitioners, such as certified nurse anesthetists, licensed clinical social workers, clinical psychologists, and registered dietitians or nutrition professionals may also furnish services.

No. It is imperative during this public health emergency that patients avoid travel to facilities where they could risk their own or others’ exposure to further illness. To the extent the waiver requires that the patient have a prior established relationship with a particular practitioner, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency.

Currently, CMS allows for use of telecommunications technology, such as mobile devices, that have audio and video capabilities that are used for two-way, real-time interactive communication. HHS has relaxed HIPAA requirements for a telehealth visit, explicitly permitting the use of FaceTime, Facebook Messenger Video Chat, Google Hangouts and Skype. Public-facing video applications such as Facebook Live, Twitch and Tik Tok are not permitted.

To learn more about offering telehealth services at your practice, download VHAN’s implementation guide here.

For the duration of the emergency, Medicare will pay for telehealth services furnished to beneficiaries “in all areas of the country in all settings” at the same rate of as regular, in-person visits.

Medicare telehealth services are generally billed as if the service had been furnished in-person. CMS asked that the Place of Service (POS) be selected based on where the physician would have otherwise performed the service. For office visits, that would typically be POS – 11, Physician Office. Claims submitted with POS 02 will be paid at the facility rate. CMS also changed the effective date to March 1, 2020.

If you need help finding the correct telehealth billing and diagnostic codes, download our coding guide here.

Medicare pays the same amount for telehealth services as it would if the service were furnished in person. For services that have different rates in the office versus the facility, Medicare uses the facility payment rate when services are furnished via telehealth. The telehealth waiver will be effective until the public health emergency declared on January 31, 2020 ends.

The use of telehealth does not change the out-of-pocket costs for beneficiaries. Beneficiaries are generally liable for their deductible and coinsurance; however, HHS is allowing healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.

Billing for Medicare telehealth services is limited to professionals. If a beneficiary is in a healthcare facility (even if the facility is not in a rural area or not in a health professional shortage area) and receives a service via telehealth, the healthcare facility would only be eligible to bill for the originating site facility fee, which is reported under HCPCS code Q3014. But the professional services can be paid for.

For any questions related to billing codes, diagnostic codes, place of service modifiers (POS) or COVID-19 diagnostic and lab tests, please refer to the VHAN Telehealth Coding Guide. If you have additional questions, please reach out to us at and we will direct you to someone who can help.

Yes. Qualified providers should inform their patients that services are available via telehealth.

Services should only be reported as telehealth services when the individual physician or professional providing the telehealth service is not at the same location as the beneficiary.

A virtual check-in pays professionals for brief (5-10 min) communications that mitigate the need for an in-person visit, whereas a visit furnished via Medicare telehealth is treated the same as an in-person visit, and can be billed using the code for that service, using place of service 02 to indicate the service was performed via telehealth. An e-visit is when a beneficiary communicates with their doctors through online patient portals.

If you need help finding the correct telehealth billing and diagnostic codes, download our coding guide here.

No. Telehealth flexibility applies regardless of the patient’s diagnosis.

States have broad flexibility to cover telehealth through Medicaid. No federal approval is needed for state Medicaid programs to reimburse providers for telehealth services in the same manner or at the same rate that states pay for face-to-face services. More information is available here.

State laws and regulations identify the providers who may perform telehealth encounters in that state. In general, any provider participating in telehealth must be licensed to practice in the state where the patient is located. HHS issued a regulation permitting doctors to practice across state lines. In addition, a large number of states have already lifted their own regulations to permit out-of-state doctors, and it is likely that more will be doing so in the near future. CMS has waived this requirement for Medicare patients and that states may request a waiver for Medicaid patients.

The Federation of State Medical Boards has also posted a chart tracking which states have altered their telemedicine license policies.

Every state requires that a patient affirmatively consent to a telehealth encounter. This consent should be documented in the EHR. There is no difference between documenting a regular visit and documenting a telehealth visit. Continue documenting notes with your EHR as you would for a face-to-face visit.

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