Apr 3, 2020 | Uncategorized
Unfortunately, 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.
Apr 3, 2020 | Uncategorized
nnMedicare now recognizes the important work that primary care physicians do when it comes to preventive screenings in older patients. Is your practice currently following the annual wellness visits for Medicare beneficiaries? Read below to find out the 3 steps to add annual Medicare wellness visits in your practice!nnDoes your practice currently conduct annual wellness visits (AWV) for your Medicare beneficiaries? These AWV’s can create a great source of revenue for your practice while allowing your patient’s an outlet to make sure they are staying healthy and enhancing their quality of life. One of the benefits of an AWV is that a practice can implement a workflow that allows all members of the care team to participate, thus maximizing the patient benefit and practice revenue. To get your practice on board to start this type of encounter, it is more than just reporting a different code. The Medicare AWV consists of several elements that must be completed during the encounter in order for the codes to be supported. You must implement an appropriate workflow to ensure all required elements or the AWV are addressed and well documented. You must also make sure your patients understand the process and what their expectations for these visits will be.nnHere is the link to the CMS MLN on this topic.nn
Apr 2, 2020 | Uncategorized
The Trump administration has released information regarding financial relief for Medicare providers. Read below for more information and see what criteria the provider or supplier must meet to qualify.nnUnder the President’s leadership, the Centers for Medicare & Medicaid Services (CMS) is announcing an expansion of its accelerated and advance payment program for Medicare-participating health care providers and suppliers, to ensure they have the resources needed to combat the 2019 Novel Coronavirus (COVID-19). This program expansion, which includes changes from the recently enacted Coronavirus Aid, Relief, and Economic Security (CARES) Act, is one way that CMS is working to lessen the financial hardships of providers facing extraordinary challenges related to the COVID-19 pandemic and ensures the nation’s providers can focus on patient care. There has been significant disruption to the health care industry, with providers being asked to delay non-essential surgeries and procedures, other health care staff unable to work due to childcare demands, and disruption to billing, among the challenges related to the pandemic.n
“With our nation’s health care providers on the front lines in the fight against COVID-19, dollars, and cents shouldn’t be adding to their worries,” said CMS Administrator Seema Verma. “Unfortunately, the major disruptions to the health care system caused by COVID-19 are a significant financial burden on providers. Today’s action will ensure that they have the resources they need to maintain their all-important focus on patient care during the pandemic.”
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Medicare provides coverage for 37.4 million beneficiaries in its Fee for Service (FFS) program and made $414.7 billion in direct payments to providers during 2019. This effort is part of the Trump Administration’s White House Coronavirus Task Force effort to combat the spread of COVID-19 through a whole-of-America approach, with a focus on strengthening and leveraging public-private relationships.
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Accelerated and advance Medicare payments provide emergency funding and address cash flow issues based on historical payments when there is a disruption in claims submission and/or claims processing. These expedited payments are typically offered in natural disasters to accelerate cash flow to the impacted health care providers and suppliers. In this situation, CMS is expanding the program for all Medicare providers throughout the country during the public health emergency related to COVID-19. The payments can be requested by hospitals, doctors, durable medical equipment suppliers, and other Medicare Part A and Part B providers and suppliers.
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To qualify for accelerated or advance payments, the provider or supplier must:
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- Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s/ supplier’s request form,
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- Not be in bankruptcy,
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- Not be under active medical review or program integrity investigation, and
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- Not have any outstanding delinquent Medicare overpayments.
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Medicare will start accepting and processing the Accelerated/Advance Payment Requests immediately. CMS anticipates that the payments will be issued within seven days of the provider’s request.
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An informational fact sheet on the accelerated/advance payment process and how to submit a request can be found here.
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This action, and earlier CMS actions in response to COVID-19, are part of the ongoing White House Coronavirus Task Force efforts. To keep up with the important work the Task Force is doing in response to COVID-19, click here. For a complete and updated list of CMS actions, and other information specific to CMS, please visit the Current Emergencies Website.
Mar 31, 2020 | Uncategorized
Ginger Avery, CPC, CPMA, CRC, is the Coding and Compliance Manager at Welter Healthcare Partners, Inc. Below, she provides information regarding Telehealth and Telemedicine reporting. Read below for important updates and whether other important information is fact or fiction. Also, check out the new AMA scenarios for telehealth, COVID-19 coding guidance here, released 03/26/2020. Click here for the AMA quick guide to telemedicine in practice.n
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. Telehealth 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 Emergency nnAsynchronous = “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. nnFact: These visits must have interactive 2-way video communication (synchronous). nnFact: Place of Service (POS) should be “02” telehealth. nnFact: Must be MD, DO or mid-level (aside from 99201/99211). nnFiction: If a patient calls in, you can charge an office visit code 99201-99215. Phone calls are NOT considered a 2-way video. nnFiction: You can charge New Patient visits codes for Established Patient visits. Services provided should reflect actual code descriptions. n
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 telehealth These 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 Inpatient nnFact: These visits must have a saved 2-way video communication. nnFact: Must be MD, DO or mid-level. nnFact: Consultations must provide evidence that a request for service from attending was conducted as well as plan/treatment recommendation was communicated back to requesting clinician. n
Virtual Check-In (Telemedicine)
n G2010 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 appointment Physicians 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 discussion *A brief (5-10 minutes) check-in with a 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 the visit was conducted via telephone ’02’ telehealth or other telecommunications device ’11’ office. nnFact: For established patients only. Fact: Must be MD, DO or mid-level. nnFact: 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. nnFact: Patient consent needs to be documented to receive virtual check-in services. n
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, the cumulative time during the 7 days; XX minutes These 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. nnFact: Medicare Fee Schedule indicates Colorado reimbursement rates from $15.52 – $50.16 for these services. nnG2061 – G2063 Qualified non-physician health care professional online assessment, for an established patient, for up to 7 days, a cumulative time during the 7 days; XX minutes These 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. nnFact: Medicare Fee Schedule indicates Colorado reimbursement rates from $12.27 – $33.92 for these services. nnFact: The patient initiates communication through an EHR portal, secure email or other digital application. nnFact: Patient consent should be documented to receive virtual check-in services. Fact: For established patients only. n
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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 patient’s 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 the 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:
n The 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 Services
Mar 30, 2020 | Uncategorized
Today we celebrate and are extremely grateful for all of our healthcare providers who are on the front line treating and caring for patients. We thank you from the bottom of our hearts for your unwavering dedication to keeping all of us safe and well!
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Mar 27, 2020 | Uncategorized
Big news for PTs and their patients! For the first time, PTs will be allowed to bill for e-visits under codes associated with online assessment and management services (codes G2061, G2062, and G2063). To determine the reimbursement rates for G2061-G2063, visit the CMS Physician Fee Schedule lookup tool. Medicare coinsurance and deductible would apply to the services. A March 18 CMS MLN Matters article includes more information about the e-visits and telehealth waiver. Read below for more information!nnIn the federal government’s rapidly evolving response to the coronavirus pandemic, the U.S. Centers for Medicare and Medicaid Services has announced that it is easing Medicare telehealth restrictions in ways that could allow PTs to provide “e-visits,” a limited type of service that must be initiated by the patient. Prior to this change, CMS did not recognize PTs among the health care professionals allowed to bill codes associated with the visits.nnThe change, announced midday on March 17, is part of a set of loosened requirements that CMS has adopted to expand the provision of telehealth and patient-initiated digital communications, such as e-visits, to help blunt the spread of COVID-19. For the most part, PTs remain outside the reach of these so-called “1135 waivers” related to telehealth, with one exception: a type of remote interaction CMS calls an e-visit under Medicare Part B.nnIn its 2020 physician fee schedule final rule, CMS describes e-visits as “non face-to-face patient-initiated digital communications that require a clinical decision that otherwise typically would have been provided in the office.” The code descriptors suggest the codes are intended to cover short-term (up to seven days) assessments that are conducted online or via some other digital platform and include any associated clinical decision-making.nnUnder the waivers guidance issued by CMS, Medicare beneficiaries can qualify for e-visits no matter their geographic region or physical location, meaning that the provisions have been expanded to nonrural areas and can take place with patients in their homes. The big news for PTs and their patients is that, for the first time, PTs will be allowed to bill for e-visits under codes associated with online assessment and management services (codes G2061, G2062, and G2063). To determine the reimbursement rates for G2061-G2063, visit the CMS Physician Fee Schedule lookup tool. Medicare coinsurance and deductible would apply to the services. A March 18 CMS MLN Matters article includes more information about the e-visits and telehealth waiver.nnTo qualify as an e-visit, three basic qualifications must be met: the billing practice must have an established relationship with the patient, meaning the provider must have an existing provider-patient relationship; the patient must initiate the inquiry for an e-visit and verbally consent to check-in services, and the communications must be limited to a seven-day period through an “online patient portal.”nnAlthough the patient must initiate, CMS writes in a fact sheet that “practitioners may educate beneficiaries on the availability of the service prior to patient initiation.” For example, if a patient cancels treatment because they can’t come to the clinic or are concerned about leaving home, then the PT may advise the patient that she or her can reach out to the therapists as needed.nnAlice Bell, PT, DPT, APTA senior payment specialist, says that the waiver has some very practical implications for PTs, and offers a possible scenario in which the e-visit could be useful.nn”Let’s say that, as a PT, I’ve been seeing a patient for an orthopedic condition and I am progressing the patient’s exercises,” Bell said. “The patient is unable to come into the clinic but calls me to say she’s having difficulty with one of the exercises and that the other two seem to be too easy. I could arrange an e-visit with the patient and discuss her performance of the exercises. And I could then make a determination — maybe I find that the patient is performing one of the exercises incorrectly — and I could direct the patient on the correct performance. Perhaps I also determine that two of the exercises can be progressed because the patient is improving, so I could instruct the patient in the two new exercises. After that I could advise the patient to contact me for a follow-up e-visit as needed until the patient can return to the clinic.”nnThe HHS Office of the Inspector General has also issued a policy statement that provides guidance on how it interprets the new telehealth waivers. APTA regulatory affairs staff will continue to monitor these waivers and other developments and share news with members.nn”As we’ve seen over the past few weeks, and especially during the past few days, we’re dealing with an extremely fluid situation in terms of response to the coronavirus pandemic,” said Kara Gainer, APTA’s director of regulatory affairs. “This waiver and other changes have the potential to make a difference, and we hope that CMS continues to take steps that can help providers and their patients stay healthy.”nnAPTA has issued a statement on patient care and practice management during the COVID-19 outbreak, and offers a webpage to keep members up to date with the latest news on the pandemic.nnOriginal article published on apta.org
