Hierarchical Condition Categories and COVID-19

As the Risk Adjustment payment models become more and more commonplace, it is important that we not forget about this when coding during our current public health emergency (PHE). Read below to find out more about hierarchical condition categories.nnHierarchical condition categories, or HCC’s, are assigned to diagnosis codes and reflect an aggregated value that is assigned based on illness severity. When we talk about COVID-19 and diagnosis correct coding, we have a new U code for reporting however there is code specific guidance we also must consider. When we report code U07.1 [ COVID-19], important to remember codes B34.2 [Coronavirus infection, unspecified], B97.2- [Coronavirus as the cause of diseases classified elsewhere], J12.81 [Pneumonia due to SARS-associated coronavirus], or J80 [Acute respiratory distress syndrome]. All of these codes should be used to identify manifestations associated with their COVID-19 diagnosis. Of these, only J80 is currently assigned an HCC value.nnGuidance is changing by the day and sometimes by the hours so it is important to make sure you are staying up to date with all guidance from CMS, WHO, and private payers.nnClick here for Official Coding and Reporting Guidelines

Stimulus Program Updates

The Federal Government has introduced various programs to make funds available to individuals and businesses during this Public Health Emergency (PHE). Currently, there are options available for providers and practices to receive funds through multiple programs, including the Coronavirus Aid, Relief, and Economic Security (CARES) Act and the CMS Accelerated and Advanced Payment Program. Here you will find a summary of these programs as well as a breakdown of how you may receive funds, what the funds are for, and the conditions for use. Click here to download the PDF of Specific Provider Programs.nnnnHelpful Links and Resourcesn

Documentation of Limitations of Care During COVID-19

Great documentation is going to be key during these uncertain times of COVID-19. For any clinician who has gone through an audit, chances are their auditors have said “tell me a good story” more than once during the process.nnTelling a good story is so important and often times even something that seems obvious to the clinician and trivial to include in a note can leave out vital information.nnHere is one example that was given by NHPCO during one of their webinars; Telehealth visits for this patient to protect patients and caregivers from illness, due to global pandemic, national state of emergency, and shortage of uninfected nurses. I spoke with this patient and his wife via telehealth. Inspection of wound and information from family shows that there has been a decrease in redness on the heels, pain maintained at 2/10 with current regimen……no in-person visit required at this time, will check in via telehealth in 48 hours, the family has instructions for crisis contact 24/7. This example checks so many boxes and in just 2 short sentences it completely sets the scene for what to expect from the encounter. It outlines the limitations of care and why it was important to have a telehealth visit with this patient.nnWhat statements are your clinicians using during this time?nnClick here for more information from NHPCOnn 

Picturing Telehealth in a Post-Pandemic World

Telehealth has become a very popular service due to the COVID-19 pandemic. Before this pandemic, 49% of people said they would use telehealth instead of an in-person visit. This has all started to change. Now 60% of people are saying that the COVID- 19 pandemic has increased their willingness to try telehealth. Keep reading the article below to find out more about what medical professionals are saying about the future of telehealth.  nnSeemingly overnight, the United States has gone from hesitant about telehealth to embracing it, with COVID-19 forcing people out of their doctor’s offices and onto their laptops, smartphones, and tablets.nn”I don’t think healthcare delivery, billing or coding will ever be the same,” Kem Tolliver, CMPE, CPC, CMOM, president of Medical Revenue Cycle Specialists in Maryland, tells HealthLeaders. “As an industry, I think we’ve been forced to innovate, not just for the sake of reimbursement but to stop the spread of a deadly virus.”nnCertainly, reimbursement for telehealth is the most important factor in boosting usage. But another, maybe overlooked, element in the telehealth boom is the sudden use of the technology by swaths of consumers and providers who may not have ever done so otherwise.nn”Telehealth has been around for a long time, and yet the US population has been relatively slow to adopt this mode of receiving care in large numbers,” Gurpreet Singh, partner and health services leader at PwC, tells HealthLeaders. “Prior to the pandemic, 49% of consumers with employer coverage said they are willing to use telehealth in place of an in-person visit.”nnHowever, consumer attitudes seem to be quickly changing. According to a new SYKES consumer survey fielded in late March:n

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  • 73% said they would consider using a telehealth service to be screened for COVID-19
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  • More than one in ten people said they’ve already used a telehealth service for something related to COVID-19, most commonly among the 18 to 24 age group
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  • 60% said the COVID-19 pandemic has increased their willingness to try telehealth
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nWhether this increased demand for telehealth continues post-pandemic depends largely on two main factors: Government rules and reimbursement remaining relaxed and a willingness by patients and providers to try the technology.nn”The game-changer for telehealth post-pandemic is a whole new population will now have the experience of using the technology for the first time,” Singh says. “Generally, consumers are reluctant to try new care delivery methods, but many are getting a crash course in the experience now.”nnThe same is true for healthcare providers, even those who have never used the technology until very recently.nn”The pandemic has not only increased consumer experience with telehealth but also clinician experience. Many doctors and nurses are becoming telehealth providers out of necessity. Health organizations are finding it is a great way to keep clinicians productive that may be in quarantine or unable to work in an in-person setting,” he says.nn”Post pandemic there will be a new cohort of clinicians who are experienced as telehealth providers and may want to continue to provide these services on a full-time or part-time basis.”nnReimbursement was already trending toward increased usage of the technology.nn”Payers and employers have been adding telehealth services to benefits packages and making cost-sharing for these visits lower than for visits to physician offices and emergency departments. In 2016, 41% of employers offered the benefit; in 2019, 86% did,” Singh says.nnNow, with expanded reimbursement and loosened rules in place, those numbers will certainly skyrocket even more.nn”Some plans are offering free telehealth visits for COVID-19 to minimize the number of patients presenting at emergency departments,” Singh says.nnThe key to keeping the new telehealth reimbursement and rules in place will be advocacy and getting involved in legislative efforts, says Tolliver.nn”This is really an area where health leaders can really direct legislators, to educate them, and to guide them on what’s necessary in order to keep our patients healthy,” she says. “Also, getting the input from our physicians, I think, is going to be critical in that lobbying process.”nnOriginal article published on healthleadersmedia.com

Important Payer Telehealth Updates for Colorado

The Welter Healthcare Partners team is closely monitoring the payer updates for telehealth as they continue to unfold. Please do not hesitate to contact us if you have any coding or billing issues. Ginger Avery, CPC, CPMA, CRC, is the Coding and Compliance Manager at Welter Healthcare Partners, Inc. Below, she provides information regarding important payer Telehealth updates for Colorado. Read below for these important updates and whether other important information is fact or fiction. nnClick here for Payer Updates and Resources: COVID-19 (Coronavirus).nnCheck out the new AMA scenarios for telehealth, COVID-19 coding guidance here, released 03/26/2020nnAMA quick guide to telemedicine in practicennCCHP National PolicynnCenter for Connected Health Policy CCHP State Laws & Reimbursement Policies  Updated 04/03/2020n

Definitions:

nTelehealth refers broadly to electronic and telecommunications technologies and services used to provide care and services at-a-distance.nnTelemedicine is the practice of medicine using technology to deliver care at a distance. A physician in one location uses a telecommunications infrastructure to deliver care to a patient at a distant site.nnTelehealth is different from telemedicine in that it refers to a broader scope of remote health care services than telemedicine. Telemedicine refers specifically to remote clinical services, while telehealth can refer to remote non-clinical services.nnPHE = Public Health EmergencynnAsynchronous = “store-and-forward video-conferencing,” which is the “transmission of recorded health history to a health practitioner. Asynchronous telemedicine involves acquiring medical data, then transmitting this data to a doctor or medical specialist at a convenient time for assessment offline.nnSynchronous = “live video-conferencing,” which is a two-way audiovisual link between a patient and a care provider. Synchronous telemedicine requires the presence of both parties at the same time and a communication link between them that allows a real-time interaction to take place.n

Office or other outpatient visits (Telehealth) 

n99201 – 99215 Office or other outpatient visits for the evaluation and management of a new (or established) patient.n

Fact: Place of Service (POS) should be “02” telehealth.

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Fact: Must be MD, DO or mid-level (aside from 99201/99211).

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Fiction: You can charge New Patient visits codes for Established Patient visits.

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Emergency Department or Initial Inpatient Services (Telehealth)

nG0425 – G0427 Telehealth consultation, emergency department or initial inpatient, typically XX minutes communicating with the patient via telehealth, depending on the severity/acuity of the patient (problem-focused, detailed or comprehensive).nnThese codes are used to report an initial inpatient or emergency department consultative visit or consultations that are furnished via telehealth in response to a request by the attending physician. Place of service should indicate the location at which patient resides, eg; 21 Inpatient or 23 Emergency Department nnG0406 – G0408 Follow-up inpatient consultation, limited, physicians typically spend XX minutes communicating with the patient via telehealthnnThese codes are used to report consultative visits or consultations that are furnished via telehealth in response to a request by the attending physician to follow up on an initial consultation or a subsequent consultative visit. Place of service should indicate the location at which the patient resides, eg; 21 Inpatientn

Fact: Must be MD, DO or mid-level.

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Fact: Consultations must provide evidence that a request for service from attending was conducted as well as plan/treatment recommendation were communicated back to requesting clinician. 

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Virtual Check-In (Telemedicine) 

nG2010 Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointmentnnPhysicians or other qualified practitioners review photos or video information submitted by the patient to determine if a visit is required. For asynchronous transmissions (e.g., store and forward), Place of Service should be indicated as ’11’ office.nnG2012* Brief communication technology-based service, e.g., virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussionnn*A brief (5-10 minutes) check-in with clinician via telephone or other telecommunications device. A physician or other qualified health care professional conducts a virtual check-in, lasting five to 10 minutes, for an established patient using a telephone or other telecommunication device to determine whether an office visit or other service is needed. Place of service should indicate whether visit was conducted via telephone ’02’ telehealth or other telecommunications device ’11’ office. n

Fact: For established patients only.

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Fact: Must be MD, DO or mid-level.

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Fact: Communication is not related to a medical visit within the previous 7 days and does not lead to a medical visit within the next 24 hours.

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Fact: Patient consent needs obtained to receive virtual check-in services.

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E-Visits (Telemedicine) A communication between a patient and their provider through an online patient portal.

n99421 – 99423 Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; XX minutesnnThese codes are used to report non-face-to-face patient services initiated by an established patient via an on-line inquiry (eg. secure email, EHR portal, or other digital application). Providers must provide a timely response to the inquiry and the encounter must be stored permanently to report this service. Place of Service should be indicated as ’11’ for this asynchronous service.n

Fact: Medicare Fee Schedule indicates Colorado reimbursement rates from $15.52 – $50.16 for these services. 

nG2061 – G2063 Qualified non-physician health care professional online assessment, for an established patient, for up to 7 days, cumulative time during the 7 days; XX minutesnnThese codes represent patient-initiated, digital communications that require a clinical decision that typically otherwise would have been provided in the office. Clinicians who may not independently bill for evaluation and management visits (for example – physical therapists, occupational therapists, speech language pathologists, clinical psychologists) should use G2061-G2063. Place of Service should be indicated as ’11’ for this asynchronous service.n

Fact: Medicare Fee Schedule indicates Colorado reimbursement rates from $12.27 – $33.92 for these services. 

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Fact: Patient initiates communication through an EHR portal, secure email or other digital application.

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Fact: Patient consent should be obtained to receive virtual check-in services.

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Fact: For established patients only.

nOnce an 1135 Waiver is authorized, health care providers can submit requests to operate under that authority or for other relief that may be possible outside the authority to the CMS Regional Office with a copy to the State Survey Agency. Request can be made by sending an email to the CMS Regional Office in their service area. Contact information to Request to Operate Under 1135 Waivern

1135 Waiver Facts: 1135-Waiver Info Here

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  • Consents are required. Stored recordings of verbal consent are recommended, however, written documentation supporting the services reported should clearly indicate the patients consent to treat. 
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  • HHS will NOT penalize clinicians for waiving copays/out of pocket (OOP). Clinicians are encouraged by Medicare to waive patients OOP, although this is not an official requirement. OIG OFFICIAL DOCUMENT
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  • Waiver can be for any emergent or acute problem, not just COVID19. Acuity/urgency must be evident in documentation. 
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  • Waiver is not for routine check-ups or non-urgent encounters. Ethical standards apply.
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  • The originating site requirements are waived. Clinicians and patients can communicate in their home settings. 
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  • Providers are expected to come into compliance with any waived requirements prior to the end of the emergency period.
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  • CMS has approved specific waivers & modifications only to the extent that the provider in question has been affected by the disaster or emergency.
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  • Waivers or modifications under section 1135 of the SSA may be retroactive to the beginning of the emergency period (or to any subsequent date). 
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  • The waiver or modification terminates either upon termination of the emergency period or 60 days after the waiver or modification is first published (subject to 60-day renewal periods until termination of the emergency).
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  • Visits are considered the same as in-person visits and are paid at the same rate as regular, in-person visits.
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  • To the extent the 1135 waiver requires an established relationship, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency.  This is not intended to allow billing for new office visits for established patients.
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Other Take Homes:

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  • All services should be documented/recorded and stored in the EHR to support medical necessity.
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  • Services must support actual code descriptions. Document what you do, code what you document.
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  • Check with your current payers to verify specific telehealth/telemedicine requirements. 
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  • Consider researching various intake platforms that will help assist with service communications/ requirements.
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  • Video & phone calls must be saved by recorded or written documentation in the EHR.
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  • None of the listed services in this article are billable by clinical staff.
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  • Time spent with the patient should be documented in all encounters. 
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  • HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (HIPAA):  Effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency.  
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Other Resources/References: 

nThe Medicare Newsroom Fact Sheet can be viewed in its entirety here.nnMedicare Telehealth FAQs 03/17/2020nnClick here for a complete list of Medicare covered Telehealth Servicesnn 

COVID-19 Welter Healthcare Partners Support Services

COVID-19  Welter Healthcare Partners Support ServicesUnfortunately, with the COVID-19 crisis, many providers and other healthcare organizations have had to make tough decisions regarding personnel and workflows, including staff furloughs and temporary lay-offs. While these decisions are necessary in these unprecedented times, these types of interruptions can often lead to a backlog of work creating delays in sending claims, claims payments, and overall revenue and cash flow.  It can also result in non-compliance in areas such as coding, and provider credentialing and enrollment with payers and facilities.  nnWe are here to help you get through these tough times! Welter Healthcare Partners is offering temporary and ongoing support services in the areas of outsourced coding, provider and facility credentialing and enrollment services, and financial strategy and compliance.nnIf you need assistance, please contact Jennifer Heuer, COO at 303.534.0388 or jh@rtwelter.com.