Telemedicine and COVID-19 Guide
Telemedicine allows health care professionals to evaluate, diagnose and treat patients in remote locations using telecommunications technology. There are three main types of virtual services physicians and other professionals can provide to beneficiaries:
- Telehealth visits—As of March 30, 2020, the provider can use an interactive apps with audio and video capablities that permits real-time communication between the distant site and the patient at home. Providers also can evaluate beneficiaries who have audio phone only.
- NOTE: CMS relaxed regulations on March 30, 2020, to allow telehealth visits to occur by audio only to ensure that patients have access to physicians and other providers while remaining safely at home.
- Virtual Check-ins—New and established patients in their home may have a brief communication service with practitioners via a number of communication technology modalities including synchronous discussion over a telephone or exchange of information through video or image.
- NOTE: Virtual check-in services were previously limited to established patients.
- E-visits—Established patients may have non-face-to-face patient-initiated communications with their doctors by using online patient portals.
The HHS Office for Civil Rights (OCR) announced
on March 17, 2020, that it will waive potential HIPAA penalties for good faith use of telehealth during the nationwide public health emergency due to COVID-19, including the use of FaceTime or Skype (which did not previously comply with HIPAA). It is recommended that physicians consider choosing a platform that is HIPAA compliant to avoid complications if seeing patients virtually is something you may consider doing once this public health emergency is over.
State Licensure and Regulations
With this public health emergency, the restriction that a physician must be licensed in the state where the patient is being seen has been lifted
. A physician licensed in any US state can see a patient in any location.
Different states may have additional regulations, although many have temporarily relaxed licensure requirements related to physicians licensed in another state and retired or clinically inactive physicians. Please contact your state board of medicine or department of health for up-to-the minute information for your state.
Typically, when billing for a telehealth visit, there must be an established relationship between the physician and the patient. However, in light of the current public health emergency, telehealth has been expanded to include both new and established patients for Medicare patients.
- CMS: HHS will not conduct audits to ensure that an established relationship existed for claims submitted during the Public Health Emergency.
- Private Payers: Some private payers are following CMS’s guidance during this public health emergency. Check with the specific payer to see if there are any limitations on coverage.
Originating Site (Patient)
- CMS is waiving the originating site requirements during the public health emergency. Medicare will pay for telemedicine services regardless of where the patient is located, including in their homes.
- Some private payers are following CMS’s guidance during this public health emergency. Check with the specific payer to see if there are any limitations on coverage.
Insurance and Co-Pays
- CMS—the use of telemedicine does not change the out-of-pocket costs for beneficiaries with Original Medicare. Beneficiaries are generally liable for their deductibles and coinsurance; however, the HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.
- Some private payers are waiving co-pays and cost-sharing. Make sure to review the payer’s website or contact the payer directly for information specific to each individual payer.
Coding for Telemedicine
Providers can bill for telehealth visits at the same rate
as in-person visits.
How to Set Up Telehealth Capabilities in Your Practice
If you do not currently have telehealth capabilities set up in your practice, the AMA has put together several resources to aid you:
Quick Start Guide
Digital Health Playbook
On March 30, 2020, CMS issued temporary regulatory waivers to equip the American healthcare system with flexibility to respond to the public health emergency. Many of these regulatory waivers further promote telehealth in Medicare. Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries.
For more specific information on the COVID-19 waivers and rule changes please visit these webpages:
Physician and Other Clinicians: CMS Flexibilities to Fight COVID-19 Fact Sheet
CMS Press Release
If you have specific questions about your practice or handling specific types of patients, please post your question to AANEM Connect: https://www.aanem.org/Membership/Member-Portal/AANEM-Connect
. AANEM staff will monitor this site for trending issues or questions to help guide the development of future resources and will also allow for quicker, crowdsourced responses from leaders in NM and EDX medicine.
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