CMS Opens Office to Cut Red Tape for Providers

Jun 25, 2020 | Uncategorized

CMS is focusing on cutting red tape for healthcare providers, leading to an extreme reduction in unnecessary work hours and a huge amount of savings for businesses in the medical field. Read below for more details on the benefits that resulted from the red tape reduction.nnRegulatory reductions are expected to save providers $6.6 billion and 42 million unnecessary burden hours through 2021.nnKey TakeawaysnnTo determine where to trim red tape, CMS relied on input from 10 Requests for Information, along with listening sessions, site visits, feedback from more than 2,500 stakeholders.nnCMS says it has already removed unnecessary and burdensome regulations that have saved providers 4.4 million paperwork hours and $800 million.nnThe Centers for Medicare & Medicaid Services on Tuesday announced the creation of a new office designed to cut red tape for providers.nnThe Office of Burden Reduction and Health Informatics was launched under the CMS’ Patients Over Paperwork Initiative, and President Donald Trump’s 2017 executive order to “Cut the Red Tape,” CMS said in a media release.nnThe regulatory reductions are expected to save providers $6.6 billion and 42 million unnecessary burden hours through 2021, CMS said.nn”The work of this new office will be targeted to help reduce unnecessary burden, increase efficiencies, continue administrative simplification, increase the use of health informatics, and improve the beneficiary experience,” CMS Administrator Seema Verma said.nnTo determine where to trim red tape, CMS relied on input from 10 Requests for Information, along with listening sessions, site visits, feedback from more than 2,500 providers, clinicians, administrative staff, and beneficiaries, and 15,000 comments from various stakeholders.nnSo far, CMS said, the red tape reductions have:n

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• Removed unnecessary, obsolete, or excessively burdensome conditions of participation for providers saving 4.4 million paperwork hours and total projected savings to providers of $800 million annually.

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• Removed 235 data elements from 33 items on the Outcomes and Assessment Information Set assessment instrument for home health.

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• Established within the Quality Payment Program consolidated data submission for the Merit-based Incentive Payment System, removing a requirement that clinicians submit data in multiple systems.

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• Eliminated 79 measures under the Meaningful Measures Initiative, resulting in projected savings of $128 million and an anticipated reduction of 3.3 million burden hours through 2020.

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• Accelerated processing state requests to make program or benefit changes to their Medicaid programs through the state plan amendment and section 1915 waiver.

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nThe Office of Burden Reduction and Health Informatics will also focus on creating efficiencies for health informatics, particularly as it relates to interoperability and leveraging new technology and automation to create new tools that allow patients to “own” their personal health data.nn“The work of this new office will be targeted to help reduce unnecessary burden, increase efficiencies, continue administrative simplification, increase the use of health informatics, and improve the beneficiary experience.”nnOriginal article published on healthleadersmedia.comnn 

Stress Caused by Taking Time-Off

Jun 25, 2020 | Uncategorized

As many of us in the healthcare industry have stayed particularly busy throughout the past few months, it’s important to remember the need for time-off. Even though current situations have many of us canceling or changing vacation plans, one aspect of time-off is always the stress involved with being away. Read below for more on the importance of taking time off from work.nnRecent polls show that over half of Americans do not take vacation time. Elizabeth Grace Saunders, a time management coach, wrote a great article in 2018 for Harvard Business news sitting four steps to help manage or relieve the stress that is associated with extended time-off. One of the most important being to “sign off”.nnWe constantly have work around us because of our cell phones. This can be one of the most challenging aspects for so many of us to not pick up the phone every time we hear a notification. Saunders also emphasizes the need to prioritize the items that can be put on hold while you are away.nnSo send your supervisor that time-off request that you have been holding onto and go enjoy some time away from work!nnClick here for more information on how to take the stress out of taking time off!

Physician Practices Pursue Four Financial Strategies To Survive Pandemic

Jun 19, 2020 | Uncategorized

nnThe COVID-19 pandemic has posed many challenges around the globe, but one major setback this virus has created is the lack of finances within physician practices. In order to combat this issue and keep healthcare resources at it’s finest, below are some strategies that can be used to save your funds.nnThe COVID-19 crisis has been a financial fiasco for physician practices, including decreased patient volume and canceled elective surgeries.nnThere are strategies physician practices can pursue to weather the financial storm associated with the coronavirus pandemic.nnNinety-seven percent of physician practices experienced a negative financial impact from the coronavirus disease 2019 (COVID-19)nnpandemic, according to a Medical Group Management Association survey published in April. The financial hits have included decreased patient volume and loss of income associated with the canceling of elective surgery.1qnnThe COVID-19 pandemic poses an existential threat to the primary care sector, says Ann Greiner, president and CEO of the Primary Care Collaborative in Washington, D.C. “If we do not respond to the financial challenges that primary care is facing, we are going to see an already damaged foundation of our healthcare system crumble.”nnPhysician practices can pursue four primary strategies to keep their business finances afloat, says Al Crawford, chairman, CEO, and co-founder of Davie, Florida­–based Bankers Healthcare Group.nn1. HOLD ON TO CASHn”Do not spend if you do not have to spend. You should just hoard cash. The more access you have to cash, the better,” Crawford says.nnDuring the COVID-19 pandemic, physician practices should limit new spending to practice enhancements related to the pandemic such as air purification systems, he says. “There are expenses required during the COVID-19 pandemic, but I recommend that you do not go beyond those required expenses in an environment like this. We are inthe middle of a pandemic, and what you do not need you should not buy.”nn2. DON’T PAY OFF DEBT, YETn”I would not be looking to pay down debt right now because of the No. 1 principle—cash is king,” Crawford says.nnMedical professionals should be careful about taking cash and paying down debt, he says. “For the next 90 to 180 days, I would try to stay cash-rich. If we’rennall back to work, there is a vaccine in the fall, your practice business is good, and you have saved a lot of money by being ultraconservative, then I would look at paying my debt down.”nnAlthough the Federal Reserve System has been taking actions to promote lending, physician practices cannot count on finding a lender if they experience a cash crunch, Crawford says. “You do not want to pay debt off, then something does not go right, and you go back to the banks and the banks are not lending. Then you do not have access to capital and that can kill your business.”nn3. USE GOVERNMENT ASSISTANCEnCrawford is bullish on the U.S. Small Business Administration’s Paycheck Protection Program (PPP).nn”You have an interest-free period for 24 weeks, which is fantastic. It is probably one of the best gifts that the U.S. government has ever given. If you follow the rules, such as spending 60% of your funds on payroll, and you get the loan forgiven at the end of 24 weeks, it is a home run,” he says.nnEven if a physician practice cannot get a PPP loan forgiven, the debt terms are a bargain, Crawford says. “If you can’t get the loan forgiven or you can’t pay your rent, it is an inexpensive loan. It is a 1% interest rate loan. So, it may make sense to do the 30-month payback and carry the loan if you can’t financially afford to bring your staff back.”nnFor physician practices that have gotten PPP assistance, the funds should be kept in a dedicated account to pay for program-approved expenses such as payroll and rent, he says. “When a practice pays for insurance or pays for payroll, they should reimburse out of the separate PPP account for the exact, specific payments. If they are making specific payments for rent, insurance, or payroll, they will have the proof for the bank and for SBA that the PPP funds were used for the purposes outlined.”nnPPP has been a lifeline for the Brownsville, Texas–based general surgery practice of Carlos Barba, MD. The cancellation of elective surgery in Texas hit the practice hard, Barba says.nnThe general surgery practice has a 10-member staff, including another surgeon and a physician assistant. “Fortunately, the federal government created the small business assistance program. We applied to that program, and I was able to get a loan. I did not have to reduce hours or cut my staff,” he says.nn4. APPLY FOR PRIVATE LOANSLending from banks and brokers also can stabilize a physician practice’s finances, Crawford says.nnBankers Healthcare Group has established an “assistance loan” that ranges as high as $500,000. Borrowers do not have to make a payment on the loan for the first 89 days.nnThe terms of the assistance loan can be crafted to limit the size of monthly payments, Crawford says.nn”We are giving the medical professional a term that goes out as long as 10 years. For the borrower, the additional years lower the monthly payment. In my opinion, right now everything is about the monthly payment. If you can lower the monthly payment, increase your savings, and decrease your spend, you have a much better shot of getting the business back to running well,” he says.nnPRIMARY CARE PAYMENT REFORMnReimbursement for primary care services must be reformed, Greiner says.nn”This pandemic has laid bare that fee-for-service has been an epic failure. It is a system that is based on face-to-face visits, which obviously does not work in a pandemic when you are trying to keep both patients and clinicians safe. So, the pandemic has prompted a lot of conversation both at the national level and the state level about moving to a prospective payment system,” she says.nnDuring the pandemic, the Centers for Medicare & Medicaid Services (CMS), as well as private health plans, have moved in the right direction on advance payments, Grnneiner says. “What both CMS and private health plans have done by putting advance payments in place is help primary care practices keep their doors open. That could be a step on a path toward prospective payments, but this is a conversation that has been going on for a long time.”nnIn addition to establishing a prospective payment system for primary care, government and private payers need to provide significant and appropriate reimbursement for innovative care delivery models such as telemedicine, she says. “We have to get to a payment system that is agnostic about the way care is delivered.”nnOriginal article published on healthleadersmedia.com

Understanding When to Use Modifier -25

Jun 19, 2020 | Uncategorized

This week’s coding conundrum is regarding the Modifier -25. Not all insurers will pay you for separate E/M services even if you code in compliance with CPT rules, but this code can help you get reimbursed for the extra work you do at certain visits. Read below to find out more and contact us today to learn how we can help your business with reimbursements!nnModifier 25 continues to cause problems throughout the industry. It remains one of the most used and often abused modifiers. The Office of Inspector General (OIG) continues to monitor this with their watch list and is the trigger for many practices and provider audits. The problem is that the documentation does not adequately support both services. Remember, “If it is worth an extra reimbursement, it is worth an extra paragraph”. There are several great articles and resources to help maintain compliance with your documentation. This is not a new problem but it is one that continues to be paramount. A great article by the American Academy of Family Physicians (AAFP) from 2004 still is relevant today in 2020. And it is not just Family Practice or Primary Care physicians who are at risk.nnClick here for more information regarding Modifier -25.

CMS Encourages Resumption of In-Person Care: 8 Things to Know

Jun 12, 2020 | Uncategorized

Recently, CMS has released a new set of guidelines and considerations to encourage healthcare practices and organizations to resume in-person care. Below are 8 things to know in regards to reopening healthcare facilities. Read the article below to find out more!nnCMS is encouraging healthcare organizations to reopen facilities for non-emergency care and released a new set of guidelines and considerations for them to follow.nnMany health systems suspended elective procedures in mid-March to keep patients and providers safe and ensure the capacity to care for COVID-19 patients. Efforts to restart those procedures safely are underway.nn”While telehealth has proven to be a lifeline, nothing can absolutely replace the gold standard: in-person care,” CMS Administrator Seema Verma said. “Americans need their healthcare, and our healthcare heroes are working overtime to deliver it safely. Those needing operations, vaccinations, procedures, preventive care or evaluation for chronic conditions should feel confident seeking in-person care when recommended by their provider.”nnEight things to know:n

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1. The new guidelines are for states that are in phase two of the federal reopening plan, which means that the state or region has no evidence of a rebound and has already satisfied the Gating Criteria, which are items that states or regions needed to hit before proceeding to phase one of the reopening plan.

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2. CMS recommends that providers prioritize resuming services for at-risk populations and for procedures that, if deferred, would likely result in patient harm.

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3. Facilities should take steps to reduce the risk of COVID-19 exposure and transmission. This may include establishing a separate area where all patients can be screened for COVID-19 symptoms. It also includes dedicating a separate space for COVID-19 patients and avoiding crossover of patients, staff and supplies.

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4. It is recommended that clinical staff who work with COVID-19 patients, or in a unit that may be exposed, are screened upon arrival and tested when appropriate.

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5. The number of visitors allowed in a hospital or outpatient site should still be minimized, CMS said.

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6. For hospitalized patients or those undergoing an operation, testing for COVID-19 should be prioritized and performed 24 hours prior to the procedure. If a test is not available, patients should self-isolate for 14 days.\

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7. CMS also recommends that staff wear surgical face masks at all times in the facility, unless they are working with COVID-19 patients and need an N95 respirator.\

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8. The workforce must be sufficient and able to adjust and respond quickly to support COVID-19 care if necessary.

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nOriginal article published on beckershospitalreview.com

Prescription Drug Management in E&M Services Does Not Mean a Level 4 Procedure Code

Jun 12, 2020 | Uncategorized

Changes in E&M coding are important to go over including information regarding prescription drugs. This week’s coding conundrum goes over the parts of the table of risk and medical decision making. Read below to find out more!nnAs 2021 approaches and we think about the changes to evaluation & management (E&M) coding it’s more important than ever to really spend some time to break down what medical decision making (MDM) means and how to assign the correct level.nnMDM consists of 3 individual parts, but often it’s only the table of risk that is considered in choosing a level. Like for instance that if you write a prescription that is an automatic level 4. Wrong!nnIn the example of an established patient with well-controlled hypertension and allergies, they are at the clinic for a routine follow-up and prescription refill. They are feeling well with no other complaints. You review their most recent lab work which is within normal limits, write a prescription for the refill and the patient agrees to follow-up again in 6 months. This would be coded to a level 3, 99213, E&M visit.nnTo break it down, MDM part A would equal two, two stable established problems. MDM part B would equal one, review of lab work. And MDM part C would be of moderate risk for two stable chronic problems and prescription drug management.nnBased on our guidelines in CPT; “To qualify for a given type of decision making, two of three elements in Table 1 must be met or exceeded”. Below is a copy of the table referenced.nn

Table taken from an article by AAFP

Colorado COVID-19 Telehealth & Billing Updates

Jun 2, 2020 | Uncategorized

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. Below is updated information regarding COVID-19 Telehealth and billing updates. Click here to download the PDF. n

Payer Updates & Resources: COVID-19 (Coronavirus)

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Payer Telemedicine Resources:

nAetna – COVID-19: Provider ResourcesnnAnthem – Information from Anthem for Care Providers about COVID-19nnCigna – Cigna’s Response to COVID-19nnHumana – Provider Resources for COVID-19nnMedicare (Novitas) – Coronavirus COVID-19 InformationnnHealth First Colorado – Telemedicine Provider InformationnnRocky Mountain Health Plans – Telehealth FAQs for ProvidersnnUnitedHealthcare – COVID-19 Information & Resourcesn

Additional Resources:

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• Colorado Department of Public Health & Environment (CDPHE

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• US Department of Health & Human Services – Telehealth 

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• AMA Quick Guide to Telemedicine in practice 

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nPart B Newsn

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• Home Visits Allowed

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• HIPAA COVID-19 Exception

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nCCHPCA Updatesn

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• Telehealth Coverage and Policies in the time of COVID-19 to date

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• COVID-19 Related state Actions

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• Telehealth Resources

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American Academy of Dermatology’s Guide to Sunscreen

Jun 2, 2020 | Uncategorized

Summer is here and many people are spending more time outside, swimming and taking vacations. It is very important to wear your sunscreen to protect yourself from the sun. Read below for more information from the American Academy of Dermatology about the importance of sunscreen!nnWith the “Official start of summer” (a.k.a Memorial Day) officially past and the reopening of many beloved outdoor activities after the shutdown from COVID-19, it’s more important than ever to remember your sunscreen.nnEspecially after so many of us just spent months indoors. The American Academy of Dermatology (AAD) has a great two-minute video as well as 5 tips for proper sun protection.nnSo get outside, enjoy your favorite activities, and do not forget to apply that sunscreen, it’s finally summer!nnClick here to read more on Sunscreen from the AAD.

PATIENTS EQUALLY SATISFIED WITH VIRTUAL ENCOUNTERS COMPARED TO IN-PERSON VISITS

May 29, 2020 | Uncategorized

The number of people using telehealth has grown tremendously since the COVID-19 outbreak. Many patients are equally satisfied with virtual encounters rather than their in-person visits to the doctor. Read the article below for more on the survey given to patients regarding telemedicine and what they preferred about their virtual visit.nnThe advent of COVID-19 has fueled the rise of telemedicine, accelerating growth beyond what was even imaginable only three months ago. Along with this phenomenon, a related mystery has been seemingly solved: can patients be as satisfied with virtual interactions as they are with in-person encounters?nnAccording to a new, large-scale Press Ganey survey, that answer is yes. The South Bend, Indiana-based company, known for its patient satisfaction surveys, took a deep look into comparing the two forms of provider-patient interactions and found that “virtual visits can achieve similar ratings for patient experience as in-person visits, with some specific differences in methods of care delivery,” according to a news release.nn“The rapid adoption of telehealth has enabled caregivers to meet the needs of patients with the levels of attentiveness, expertise, and empathy provided during an in-office visit,” said Patrick T. Ryan, chairman, and CEO of Press Ganey. “If caregivers actively adapt their processes and behaviors to the telemedicine environment, they can effectively build the unbreakable bonds of trust that are so critical to patient-centered care.”nnThe survey was conducted over a six-week period concluding at the end of April and includes more than 30,000 responses. During that time respondents reported nearly 70% of their encounters involved a full or mixed virtual medicine component. Mixed visits could have included a combination of video and in-person visits, telephone, email, or text.nn”Based on the data, patients are overwhelmingly positive about their virtual interactions with their care providers, even when technical issues posed challenges,” according to The Rapid Transition to Telemedicine: Insights and Early Trends, issued by Press Ganey. A chart in the report demonstrates tight alignment between patient’s satisfaction scores for virtual or in-person visits when asked about their likelihood of recommending care provider, the provider’s concerns for their questions or worries, efforts to include them in decisions, explanations of problems and conditions, treatment discussions, and “whether the staff worked together to care for you.”nnThe survey also indicates, however, opportunities to improve processes related to telemedicine. For example, ease of scheduling appointments and ease of contacting the provider scored much lower for virtual care versus in-office visits. As a result, patients are less likely to recommend virtual visits to others compared to office encounters.nn”This is not unexpected given the quick, large-scale transition to telemedicine and the learning curve for the provider and the patient,” the report states. “These data highlight opportunities for enhancing the physician-patient connection by addressing technical barriers that impede consistent and reliable communication.”nnThe report suggests several recommendations to help providers enhance the patient experience when conducting virtual visits:n

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• Be genuine and conscious of the warmth conveyed during the opening and closing of each session. Confirm that the patient can hear and see you clearly and avoid interruptions.

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• Set an agenda at the outset. Identify and confirm the patient’s priorities and communicate how they will be addressed.

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• Consistently convey empathy through language. Deliberately check in about patients’ worries or concerns throughout the visit and especially at the end of the session.

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• Bring structure to officially closing out the session. Summarize the post-visit plan, reinforcing patient, and provider actions. Review questions and answers. Offer instructions for follow-up concerns.

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nOriginal article published on healthleadersmedia.com

Codes Z55-Z65 Social Determinants of Health

May 29, 2020 | Uncategorized

This week’s code spotlight highlights the social determinants of health codes that deal with many factors including prescribed medications or a patient’s BMI. Read below for more information on some of the benefits of including social determinants of health in reporting.nnAs the health care industry sees an increase of risk adjustment coding, the importance of correct and accurate ICD-10 coding is continuing to be an area of discussion among the various organizations. Although these codes do not carry an HCC level, from a correct coding standpoint, it is always important to code to the greatest specificity supported by the documentation. Social determinants of health (SDoH) category codes of Z55-Z65 are part of Chapter 21 [Factors Influencing Health Status and Contact with Health Services] which all deal with a wide range of factors from prescribed medications to a patients BMI. As coders, it’s important to not forget to report these codes if they are supported by the documentation. As clinicians, it is important to make sure that these factors are documented when present.nnIn a November 2019 article posted on the American Medical Associations website (aha.org) some of the benefits of including SDoH in their reporting include:n

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• Track the social needs that impact their patients, allowing for personalized care that addresses patients medical and social needs

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• Aggregate data across patients to determine how to focus on a social determinants strategy

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• Identify population health trends and guide community partnerships

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nFor hospitals, this is not a new concept. They have social workers on staff who typically are charged with documentation of these factors. This is why independent practices and outpatient services can begin doing a better job to capture these data points, and making sure our clinical staff are including these important factors in their documentation.nnClick here to read more on the social determinants of health.

House Approves New Stimulus Payments, Billions For States, In $3T Heroes Act

May 19, 2020 | Uncategorized

The House approved the Heroes Act in a 208-199 vote. The Heroes Act is a critical $3 trillion-dollar rescue for front line workers, cities, states, and small businesses. Read the article below to learn more about the Heroes Act.nnThe U.S. House late Friday approved a massive, $3 trillion coronavirus spending package that would, among other things, provide a second round of $1,200 stimulus checks, $200 billion in hazard pay for essential workers – including those at Electric Boat shipyards– and extend the federal $600-per-week unemployment benefits for six more months. The Heroes Act, was approved on a 208-199 vote, with the unanimous support of Connecticut’s House members, all Democrats.nnOriginal article published on healthleadersmedia.com

It’s Never Too Early to Start Preparing for the 2021 E/M Changes

May 19, 2020 | Uncategorized

Have you started preparing for the new 2021 E/M changes? It is never too early as much of healthcare is already changing. Read below for more information on what has prompted the changes in the healthcare system.nnWith all that 2020 has already brought to the table and the changes it has prompted in the healthcare industry, it is important that each of us not lose track of what the future holds.nnAlthough the final rule is not scheduled to be released until November 2020, it is important that practice managers start talking, teaching, and planning now with their teams. These changes have been focused on how providers document and report E/M encounters and have been several years in the making.nnAMA’s director of editorial and regulatory services Zach Hochstetler said in a recent webinar, “We are encouraging everyone to adopt these changes now”. In addition to this, it was announced that AMA has plans to release educational and training material as well as web-based tools to assist in the transition.nnStart training your providers now to recognize the appropriate medical decision making, or MDM, level, and then driving the rest of the key elements to match this. As the new guidelines allow providers to select their level of service based on MDM or time, this will become the most important element of the encounter documentation.

What Will Never Be the Same Again in Healthcare?

May 5, 2020 | Uncategorized

Since the COVID-19 outbreak, there are certain aspects of healthcare that will never be the same. Below, CEOs of some of the biggest healthcare providers in the United States have provided their take on what they believe will never be the same in healthcare. Read the article below to find out more on their perspectives. nnThe healthcare industry’s vocabulary has avoided the word “never.” The COVID-19 pandemic has tossed aside squishy, non-committal words like “iteration” and “evolution” and replaced them with “permanently” and “over.” Healthcare leaders are facing a very different healthcare world because of COVID-19.nnHealthLeaders Exchange program director and editor Jim Molpus reached out to 17 trusted advisors to get their perspective on what will never be the same again in healthcare. The responses were passionate, diverse, and hopeful:nnVERY LITTLE WILL BE THE SAME AGAIN IN HEALTHCARE.nnI expect very little will be the same as it used to be after this pandemic is behind us. This crisis is altering—perhaps permanently—how and where providers interact with their patients and with each other, how providers approach their work, and how health systems respond individually and collectively under intense pressures. Stay-at-home and physical-distancing directives have thrust new telemedicine into the spotlight for giving patients more choices to be seen when and where they want to be seen.nnA nice-to-have service before the pandemic, virtual office visit capability is now elevated to a must-have care delivery option. This will fuel a burst of competition as providers race with urgency to expand virtual care access. I am hopeful the lessons learned during COVID-19 will drive innovation that transforms care quality, safety, efficiency, preparedness, and patient satisfaction. I am often asked if my organization, and our nation, will weather this healthcare crisis. The answer is yes, and we will be stronger. But we also understand that overcoming this threat means being changed by the experience.nnGary S. Kaplan, MDnChairman and CEOnVirginia Mason Health SystemnSeattle, WAnnTHE STATUS QUO WILL NEVER BE THE SAME AGAIN IN HEALTHCARE.nnExecutives are likely to encourage employees to work from home. Significant savings can be realized by eliminating expensive commercial space and allowing employees to work remotely. Remote workers are happier and more engaged without brutal commutes.  As appropriate, employees can now watch over their young children, take care of older or sick family members, attend important events, and enjoy a higher quality of life. It will be hard to bring everyone back from home once they have demonstrated improved productivity, wellness, happiness, and its ultimate impact on the bottom line.nnSarah RichardsonnVP Change Leadership, ITnOptumnLos Angeles, CAnnPROCESSES WILL NEVER BE THE SAME AGAIN IN HEALTHCARE.nnHospital operations will never rely so heavily on human processes again in the future. The days of relying on huge teams of humans to accomplish routine mission-critical processes are over. Health systems will hire AI workers to take on critical “keep the lights on” processes and shift their human workforce to focus on the quality of care delivery.nnSean LanenCEOnOlivenColumbus, OHnnDAY-TO-DAY HOSPITAL OPERATIONS WILL NEVER BE THE SAME AGAIN IN HEALTHCARE.nnFrom social distancing guidelines to how we greet one another, the way we manage the day-to-day operations of healthcare will never be the same. Small conference rooms will make people uncomfortable; handshakes will be frowned upon, and face-to-face meetings will be replaced by Zoom and GOTOMEETING. Losing the human connection will be a concern that everyone will think about … but I am confident that new ways of communication and operations will evolve to ensure that human contact is not lost.nnBeverly Bokovitz, DNP, RN, NEA-BCnVice President & Chief Nurse ExecutivenUC HealthnCincinnati, OHnnHEALTHCARE SPENDING WILL NEVER BE THE SAME AGAIN IN HEALTHCARE.nnThe U.S. will emerge from this pandemic with WWII levels of debt. The trillions in debt will require healthcare spending to be on a different trajectory. There are a few levers of change that can be pulled:n

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• More preventive care, but that does not appear to be solving the cost problem so far.

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• How we behave: what we eat, use of drugs/alcohol, etc.

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• Deliver less care: Other countries invest less in certain services than the U.S., such as knee/hip implants, spine fusions, cardiac caths, proton beams, etc.

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• Deliver healthcare like we deliver other services, with as much globalization and technology as possible, and the human touch has been ratioed to those paying a premium.

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nNeil CarpenternVice President of Strategic PlanningnArray AdvisorsnWashington, D.C.nnOUR COLLECTIVE SENSE OF HEALTH AND SECURITY WILL NEVER BE THE SAME AGAIN IN HEALTHCARE.nnFor most of us, health, or the lack thereof, is personal. We suffer alone with heart disease, cancer, or possibly dementia. COVID-19 is different. It touches the national psyche. Whether young or old, white or black, each of us and our family is at risk. COVID-19 presents a unique opportunity to rethink what we want from our healthcare system. As Americans, we tend to focus on the new and novel, a cure for cancer or some other esoteric disease, while ignoring ancient foes like bacteria and viruses, mundane public health concerns. What are we willing to give up in order to get a safer future for all of us?nnAlan Pitt, MDnProfessornBarrow Neurological InstitutenPhoenix, AZnnHEALTH SYSTEMS’ RELATIONSHIPS WILL NEVER BE THE SAME AGAIN IN HEALTHCARE.nnWith their team members (Did we keep you safe? Were we transparent and selfless?); with their communities (Could you count on us? Were we prepared?); with their patients (Did we show compassion even under extreme duress? Did we let a loved one die alone?); with technology (Had we already invested in reliable platforms for telemedicine, robotic process automation, virtual care, and more? Were we playing catchup, with too little too late?). Every crisis creates challenges and opportunities with relationships. A chance to make bonds stronger and more permanent, or the loss of what once was and what might have been. The COVID-19 crisis is an extreme example of this reality.nnRonald Paulus, MDnFormer CEOnMission HealthnAsheville, NCnnTHE STATUS QUO WILL NEVER BE THE SAME AGAIN IN HEALTHCARE.nnSociety’s acceptance of status-quo healthcare as acceptable is over. We now know that a suboptimal public health and healthcare system can bring our entire world to a complete stop, result in a needless number of deaths, and put our wonderful healthcare workers in unnecessary danger. Our collective demand for prioritized investment, higher standards, and embrace of innovation will become the norm. Leaders will be on notice.nnMarcus WhitneynCEO & Co-FoundernHealth FurthernNashville, TNnnHOSPITALS WILL NEVER BE THE SAME AGAIN IN HEALTHCARE.nnEmergency preparedness will be a differentiator. One in four will face insolvency unless a federal bailout keeps them afloat. Telehealth will be mainstreamed. Workforce safety will be a testy issue. Consolidation will accelerate. Insurer’s leverage, uncompensated care, and physician disaffection will heighten. And capital portfolios will be adjusted to rationalize investments more strategically.nnPaul KeckleynThe Keckley ReportnNashville, TNnnTHE HOSPITAL ADMINISTRATOR-CLINICIAN RELATIONSHIP WILL NEVER BE THE SAME AGAIN IN HEALTHCARE. nnAs someone with friends on both sides of the aisle, I believe COVID-19 has strained the relationship to the point where clinical leadership will now demand greater accountability over hospital operations and emergency preparedness. There has always been a fascinating dynamic between business-minded hospital strategy versus day-to-day patient care. However, during times of extreme duress, the clinicians on the COVID-19 front lines have disproportionately borne the brunt of the pandemic. I think there will be some tough but necessary conversations about emergency supply storage, hazard pay, sick pay, or relocation benefits to avoid family contamination moving forward.nnAndy MychkovskynHealthcare Strategy Consultant and CreatornHealthcarepizza.comnWashington, D.C.nnSPEED TO INNOVATE MUST NEVER BE THE SAME AGAIN IN HEALTHCARE.nnThis crisis has revealed the unquestionable need that we commit to human experience at healthcare’s core for those we serve and those who serve as human beings caring for human beings. It too has shown us it does not and must not take us months or years to innovate to ensure the best in care. Innovations in process, protocols, and products should no longer be stuck in extended analysis and review. We can identify, analyze, and act to address opportunities quickly and must do so in a new healthcare world that will require a delicate blend of agility and compassion.nnJason WolfnCEOnThe Beryl InstitutenNashville, TNnnFACE-TO-FACE PHYSICIAN VISITS WILL NEVER BE THE SAME AGAIN IN HEALTHCARE.nnIn the face of this pandemic, we condensed a planned 18-month rollout of our telemedicine program to just nine days. We went from zero telemedicine visits in October to a handful of doctors being trained and us all being very excited when the first video visit was conducted in November, to where we are now: nearly 3,000 telemedicine visits a day, about half of which are video visits. These are conducted by more than 800 providers across primary care and specialty care lines. This is working well for all involved. So, I don’t think we will ever go back to the old way of seeing and treating patients.nnChris Van GordernCEOnScripps HealthnSan Diego, CAnnBUSINESS STRATEGY WILL NEVER BE THE SAME AGAIN IN HEALTHCARE.nnHealthcare organizations will think about business strategy in terms of anticipating disruption versus reacting to disruption. Leaders will be thinking through their strategies as a collection of unique scenarios to be more agile, bold, and forward-thinking. Two important elements will become the foundation of many healthcare strategies—people and partnerships. Organizations that put their people at the center of strategy will engender trust, loyalty, and gain a competitive advantage. Partnerships with traditional and nontraditional healthcare organizations will be the key amplifier for growth.nnJhaymee Tynan, FACHEnAssistant Vice President, IntegrationnAtrium HealthnCharlotte, NCnnPUBLIC HEALTH WILL NEVER BE THE SAME AGAIN IN HEALTHCARE.nnMost healthcare leaders and practitioners have a belief system grounded in science and rationality and use these when committing to improving the system, at least within their vision of what is possible. It is too easy to forget that the political system which regulates public health and funds local health departments does not share or assume this thought process, and oftentimes unqualified individuals are elected to oversee and fund public health. We cannot afford any longer to assume the government is doing its job to ensure adequate public health. Perhaps now the time is right for combined political pressure from the AHA, et al., to form public interest coalitions to lobby for change at all levels of government.nnMark Herzog, FACHEnConsultant and CEO, RetirednHoly Family MemorialnManitowoc, WInnSUPPLY CHAINS FOR PHARMACEUTICALS AND ESSENTIAL MEDICAL EQUIPMENT WILL NEVER BE THE SAME AGAIN IN HEALTHCARE.nnThe COVID-19 pandemic has shown us critical deficiencies in the supply chain of essential drugs, even as basic as medications for sedation. Even with certain drugs formulated within the U.S., the APIs (Active Pharmaceutical Ingredients) are sourced from foreign countries. Most of the generic drugs in the U.S. are also sourced from Asian countries. Cost alone cannot dictate the supply chain—the proximity and accessibility will be factors that will have to be dealt with. This scenario holds true not only for pharmaceuticals, but also for medical devices and medical gear for clinicians. The next pandemic which hits us globally could very well be more potent, both in terms of its mortality and infection rate, and plans to rectify the supply chain deficiencies have to be addressed immediately.nnJay SrininChief StrategistnSCS VenturesnPittsburgh, PAnnBEING TAKEN FOR GRANTED WILL NEVER BE THE SAME AGAIN IN HEALTHCARE.nnThe assumption that while the world turns, few consider healthcare until they are in need. In the future, our world will recognize the significant impact that healthcare can have on ALL areas of our lives. Into the future, we will become much more important and relevant.nnBritt BerrettnProgram DirectornThe University of Texas at DallasnDallas, TXnnTELEHEALTH WILL NEVER BE THE SAME AGAIN IN HEALTHCARE.nnTelehealth’s rapid scale-up has been critical in the public health response to COVID-19. Now, telehealth has reached its tipping point, with consumers unlikely to revert to the previous reality once we are beyond the pandemic. Looking post-pandemic, telehealth will be critical to addressing access to care issues and helping mitigate the clinician shortage. For the former, providers must figure out sustainable pricing models that hold clinicians and patients accountable. For the latter, they will need to determine which clinicians should deliver what types of care services via telehealth and which ones should be elevated to higher levels of practice elsewhere on the continuum.nnSteven ShillnPartner and National LeadernBDO Center for Healthcare Excellence & InnovationnOrange County, CAnnOriginal article published on healthleadersmedia.com

Knowledge Sharing

May 5, 2020 | Uncategorized

During these times of social distancing, isolation, businesses being shut down, and employees being laid off, it is hard for a lot of people to feel the same fulfillment they did just a few months ago and self-pity can set in quickly. nnPerhaps you believe in the theory that there is nothing better for self-pity than you go out and help others. Volunteering is one of those opportunities that can take so many different forms. And when we relate this specifically to your career, knowledge sharing can not only be beneficial to your co-workers, networking groups, or community, but also to yourself.nnKnowledge sharing in these times can be as simple as writing a short article, hosting a virtual networking event, spending some downtime working with a co-worker, or volunteering to talk on a topic to a group. And with virtual meetings, your fear of standing in front of a group and speaking just may improve by practicing talking to a webcam.nnClick here for more about knowledge sharing.

What You Should Do Now To Prepare For Elective Surgery Demand Post-COVID-19

Apr 30, 2020 | Uncategorized

Many providers should start making preparations ahead of time for elective surgeries. Creating a prioritization model is highly recommended to determine the demand and constraints that they may encounter. Read the article below for more information on what you should do now to prepare for the elective surgery demand.nnSurgical patients are on hold, and providers have lost a valuable source of revenue to support their operations. Hospital strategists, in partnership with community surgeons, are already working to understand the financial impact. They must also now begin to create a purposeful plan for managing elective surgery demand after COVID-19.nnMuch is still unknown. But what is certain is that as regions emerge from the crisis, there will be a dramatic surge in demand for elective procedures. There is a short window right now in which our hospitals and health systems must take a data-driven approach to prioritize this pent-up demand. And develop a strategy for addressing it quickly and efficiently.nnHospital executives and surgeons must determine the demand forces that they must prioritize against:n

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1. Number of elective cases in the community per surgeon (inpatient or ambulatory)

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2. Patient condition and need for care

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3. Surgeon and case predictability by the length of the case and individual skill

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4. Revenue generation per case

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5. Length of time patient has been waiting for care

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nCreating a prioritization model requires matching those demands to facility capacity constraints:n

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1. Inpatient beds available to care for post-surgical patients

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2. Availability of personal protective equipment (PPE), such as masks, gloves, and gowns

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3. Physician preference items (PPI), such as hip replacements, knee replacements and neurosurgical screws and plates

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4. Staffing availability and skill sets, especially in light of exhausting our staffs during the crisis

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5. Timing of COVID-19 patient number decline in the current wave

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nOrganizations will have to rethink their traditional models in favor of a rapid-response mentality. You can’t resume a business-as-usual approach where hospitals try and fit the pent-up demand into their current scheduling operations. That won’t work, and it will lead to capacity constraints.nnCurrent levels of operational inefficiency, especially around traditional block schedule management, will get in the way of meeting both normal and pent-up demand. It doesn’t allow for the prioritization approach to succeed.nnIn particular, the need for a rapid post-COVID-19 response will require surgical suites to rethink their traditional individual surgeon block methodology. They’ll need to create usable free space and maximize the use of the entire operating room to meet the pent-up demand. The “rapid response” will need to include:n

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1. Boosting utilization to over 75% to allow more cases in their daily prime time. This means rethinking block management to create more capacity in the surgical suite prime-time hours.

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2. Moving less intensive procedures (such as many dental and endoscopy cases) to dedicated Procedure Rooms. This removes them from the daily caseload of the surgical suite.

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3. Expanding the hours of surgical suite availability each day well into the evening and possibly open to elective cases on weekends.

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nExecuting this strategy will require immediate action. You’ll need to use available data from both the hospital and its affiliated surgeons to:n

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• Understand community and hospital constraints

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• Rethink operational processes

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• Partner with community surgeons in ways most have never done

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nOrganizations like Optum Advisory Services are ready to help in modeling, prioritizing, and planning for the return of elective cases. Understandably, hospital executives are focused on responding to the current crisis. But there’s little time left to create a strategy to accommodate pent-up elective surgery demand. And you’ll need to rescue revenue generation so that hospitals can continue to serve their patient communities long past the current pandemic.nnOriginal article published on healthleadersmedia.comnn 

Hierarchical Condition Categories and COVID-19

Apr 30, 2020 | Uncategorized

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

Apr 21, 2020 | Uncategorized

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

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• HHS CARES Act Provider Relief Fund

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• Novitas Coronavirus Accelerated and Advance Payment Request Forms

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• Novitas Coronavirus Accelerated and Advance Payment Request Forms: Fact Sheet

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• SBA Programs

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• SBA: Payment Protection Program

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• SBA: Economic Injury Disaster Loan Emergency Advance

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• SBA: Express Bridge Loans

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Documentation of Limitations of Care During COVID-19

Apr 21, 2020 | Uncategorized

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

Apr 9, 2020 | Uncategorized

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

Apr 8, 2020 | Uncategorized

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