I just prepared this for our providers. It is in PDF format and is color-coded for easier picking out of terms. For some reason, I cannot attach that PDF to this post so I'm doing this. The information is just as good; it's just harder to read.
These are some definitions, as published in CMS articles
March 17 - 20, 2020.
1. The Coronavirus Preparedness and Response Supplemental Appropriations Act, as signed into law by the President on March 6, 2020, includes a provision allowing the Secretary of the Department of Health and Human Services to waive certain Medicare telehealth payment requirements during the Public Health Emergency (PHE) declared by the Secretary of Health and Human Services January 31, 2020 - to allow beneficiaries in all areas of the country to receive telehealth services, including at their home.
These emergency allowances exist until the emergency is declared to no longer exist.
2.
E-Visit: s/b conducted via a Patient Portal (an issue separate from Telehealth)
Telehealth: s/b conducted via an interactive audio and video telecommunications
system that permits real-time communication between the distant site (provider) and
the patient at home.
Note that Telehealth does not require a Patient Portal.
Can be conducted by smartphone, tablet, laptop, etc. (See Point 10 below)
3. Distant site practitioners who can furnish and get payment for covered Telehealth
services (subject to state law) can include physicians, nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologists, clinical social workers, registered dietitians, and nutrition professionals.
4.
No modifiers - for services performed by private practice providers.
Modifiers - for services performed by Facilities (Hospitals; ASCs; etc.)
5. Patient initiates short phone call to doctor:
(Virtual Check-Ins) Call may be placed over regular land-line phone.
- to refill prescription, ask a quick question, etc. HCPCS code G2012
- to send image for doctor to look at: HCPCS code G2010
6. Patient calls and makes appointment. Doctor calls patient at appointed time:
(Telehealth) Use Office Visit codes 99212 - 99215, and the few other relevant Codes here:
https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-CodesNote that these codes can be used only if the person making the return call to the patient
is one of those listed at Point 3 above. The guidelines say that the provider's call to patient
should be done with a smartphone, tablet, laptop, or other audio / visual device. Since
auditing will be lax or non-existant, can probably be done via land-line for those needing it.
7. The provider services allowable for Telehealth are those that the provider can
reasonably accomplish through a long-distance interface. Can take temperature
(so says CMS). Cannot draw blood / do lab tests. Etc.
Medicare pays separately for other professional services that are commonly furnished remotely using telecommunications technology without restrictions that apply to Medicare Telehealth. These services, including physician interpretation of diagnostic tests, care management services and virtual check-ins, are normally furnished through communication technology.
8. Medicare telehealth services are generally billed as if the service had been furnished in-person.
For Medicare telehealth services, the claim should reflect the designated Place of Service (POS) Code 02 - Telehealth, to indicate the billed service was furnished as a professional telehealth service from a distant site.
9. For the duration of the emergency, HIPPA Compliance is being relaxed in areas where
speedy care is essential, and in areas where mistakes are made in good faith.
10. Telehealth communication devices must be non-public facing.
A “non-public facing” remote communication product is one that, as a default, allows only the intended parties to participate in the communication. Non-public facing remote communication products would include, for example, platforms such as Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, Whatsapp video chat, or Skype. Such products also would include commonly used texting applications such as Signal, Jabber, Facebook Messenger, Google Hangouts, Whatsapp, or iMessage. Typically, these platforms employ end-to-end encryption, which allows only an individual and the person with whom the individual is communicating to see what is transmitted. The platforms also support individual user accounts, logins, and passcodes to help limit access and verify participants. In addition, participants are able to assert some degree of control over particular capabilities, such as choosing to record or not record the communication or to mute or turn off the video or audio signal at any point.
In contrast, public-facing products such as TikTok, Facebook Live, Twitch, or a chat room like Slack are not acceptable forms of remote communication for telehealth because they are designed to be open to the public or allow wide or indiscriminate access to the communication. For example, a provider that uses Facebook Live to stream a presentation made available to all its patients about the risks of COVID-19 would not be considered reasonably private provision of telehealth services. A provider that chooses to host such a public-facing presentation would not be covered by the Notification and should not identify patients or offer individualized patient advice in such a livestream.
https://www.hhs.gov/sites/default/files/telehealth-faqs-508.pdfhttps://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdfhttps://www.hhs.gov/sites/default/files/hipaa-and-covid-19-limited-hipaa-waiver-bulletin-508.pdfhttps://www.cms.gov/files/document/general-telemedicine-toolkit.pdf
