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

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

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 Notes
Aetna Updated May 20, 2020n

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  • Until June 4, 2020, Aetna will waive member cost-sharing for any in-network covered telemedicine visit – regardless of diagnosis – for their Commercial plans.
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  • Through September 30, 2020, Aetna is extending all member’s cost-sharing waivers for covered in-network telemedicine visits for outpatient behavioral and mental health counseling services for their commercial plans.
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  • Through September 30, 2020, Aetna will offer zero co-pay primary care and behavioral health telemedicine visits with network providers to all Individual and Group Medicare Advantage members
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  • For Medicare Advantage plans, effective May 13, 2020, through September 30, 2020, Aetna is waiving member out-of-pocket costs for all in-network primary care visits, whether done in-office and via telehealth, for any reason.
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  • Aetna will continue to cover limited minor acute care evaluation and care management services, as well as some behavioral health services rendered via telephone, until August 4, 2020. The member cost-share waivers for medical care for Commercial plans will end on June 4, 2020.n
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    • Self-insured programs may opt-out of cost-sharing waivers
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Anthem Update May 29, 2020n

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  • Through at least June 15, 2020, Anthem’s affiliated health plans will waive member cost-share for telehealth visits, including visits for behavioral health, for insured health plans in Colorado.
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  • Cost-sharing will be waived for members using Anthem’s authorized telemedicine service, LiveHealth Online, as well as care received from other providers.
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  • Through at least June 17, 2020, Anthem’s affiliated health plans will cover telephonic-only visits with in-network providers.n
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    • Self-insured programs may opt-out of cost-sharing waivers
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Cigna Updated May 22, 2020n

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  • Through July 31, 2020, Cigna will waive customer cost-sharing related to COVID-19 screening, testing, and treatment.
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  • Through July 31, 2020, Cigna will waive customer cost-sharing for telehealth screenings for COVID-19.
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  • Through July 31, 2020, Cigna will cover usual face-to-face E/M visits via telehealth, but standard cost-share will apply.n
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    • This is applicable for Cigna Commercial, not Cigna MA
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Humana Updated May 15, 2020n

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  • Humana will extend cost-sharing waivers through the end of the year for individual and group Medicare Advantage members. This waiver applies to audio and video telehealth visits with all participating/in-network providers, including primary care, behavioral health, and other specialist providers.
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  • As of May 15, 2020, Humana will resume pre-payment medical record claims review and post-payment medical record claims review. This will be a return to the normal Humana policy.
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  • As of May 22, 2020, Humana will reinstate authorizations and referrals for required services for Medicare Advantage, Medicaid, and Commercial lines of business. This will be a return to the normal Humana policy.n
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    • Humana will continue to suspend all medical authorizations and referrals for COVID related diagnosis
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  • Medicare (Novitas) will keep COVID-19 related telehealth changes in place for the “duration of the PHE” for services rendered on or after March 1st, 2020.
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  • Information from CMS is updated regularly, and timelines will reflect the most recent updates.
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  • Health First Colorado (Medicaid) will keep COVID-19 related telehealth changes in place for the duration of the PHE.
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  • Services can be provided between a member and a distant site provider when a member is in their home or other location of their choice. Additionally, the distant provider may participate in the telemedicine interaction from any appropriate location.
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  • Information from CMS is updated regularly, and timelines will reflect the most recent updates.
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RMHP Updated April 7, 2020n

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  • Through June 18, 2020, RMHP will waive cost-sharing for in-network, non-COVID-19 telehealth visits.
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  • Through June 18, 2020, RMHP will reimburse appropriate claims for telehealth services delivered by telephone if delivery is provided through live, interactive audio, and visual transmission.
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UHC Updated May 22, 2020n

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  • Through June 18, 2020, UnitedHealthcare will reimburse appropriate claims for telehealth for dates of service starting March 18, 2020.
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  • Through June 18, 2020, UnitedHealthcare is waiving the CMS originating site for Medicare Advantage, Medicaid, and Individual and Group Market health plan members.
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  • Through at least September 30, 2020, UnitedHealthcare will cover the full cost share for Medicare Advantage members for applicable services.
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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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nCCHPCA Updatesn

American Academy of Dermatology’s Guide to Sunscreen

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

Telehealth virtual visitsThe 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

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

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

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?

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

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

Elective Surgery Demand Post COVID-19Many 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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  3. Patient condition and need for care
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  5. Surgeon and case predictability by the length of the case and individual skill
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  7. Revenue generation per case
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  9. 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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  3. Availability of personal protective equipment (PPE), such as masks, gloves, and gowns
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  5. Physician preference items (PPI), such as hip replacements, knee replacements and neurosurgical screws and plates
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  7. Staffing availability and skill sets, especially in light of exhausting our staffs during the crisis
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  9. 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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  3. 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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  5. 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

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

Stimulus Program Updates

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

Documentation of Limitations of Care During COVID-19

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

Picturing Telehealth in a Post-Pandemic World

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

    n

  • 73% said they would consider using a telehealth service to be screened for COVID-19
  • n

  • 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
  • n

  • 60% said the COVID-19 pandemic has increased their willingness to try telehealth
  • n

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

Important Payer Telehealth Updates for Colorado

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

Definitions:

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

Office or other outpatient visits (Telehealth) 

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

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

n

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

n

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

nn

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.

n

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. 

nn

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.

n

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

n

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.

n

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

nn

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. 

n

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

n

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

n

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

n

    n

  • 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. 
  • n

  • 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
  • n

  • 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. 
  • n

  • Providers are expected to come into compliance with any waived requirements prior to the end of the emergency period.
  • n

  • CMS has approved specific waivers & modifications only to the extent that the provider in question has been affected by the disaster or emergency.
  • n

  • 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).
  • n

  • Visits are considered the same as in-person visits and are paid at the same rate as regular, in-person visits.
  • n

  • 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.
  • n

n

Other Take Homes:

n

    n

  • All services should be documented/recorded and stored in the EHR to support medical necessity.
  • n

  • Services must support actual code descriptions. Document what you do, code what you document.
  • n

  • Check with your current payers to verify specific telehealth/telemedicine requirements. 
  • n

  • Consider researching various intake platforms that will help assist with service communications/ requirements.
  • n

  • Video & phone calls must be saved by recorded or written documentation in the EHR.
  • n

  • None of the listed services in this article are billable by clinical staff.
  • n

  • 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.  
  • n

n

Other Resources/References: 

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

COVID-19 Welter Healthcare Partners Support Services

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

Medicare Annual Wellness Visits and Revenue Enhancement

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 

Trump Administration Provides Financial Relief for Medicare Providers

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.”

n

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.

n

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.

n

To qualify for accelerated or advance payments, the provider or supplier must:

nn

    n

  • Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s/ supplier’s request form,
  • n

  • 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.
  • n

n

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.

n

An informational fact sheet on the accelerated/advance payment process and how to submit a request can be found here.

n

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.

Telehealth/Telemedicine Reporting for Medicare: Fact or Fiction

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

1135 Waiver Facts: 1135-Waiver Info Here 

n

    n

  • 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. 
  • n

  • 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 
  • n

  • Waiver can be for any emergent or acute problem, not just COVID19. Acuity/urgency must be evident in the documentation. 
  • n

  • Waiver is not for routine check-ups or non-urgent encounters. Ethical standards apply. 
  • n

  • The originating site requirements are waived. Clinicians and patients can communicate in their home settings. 
  • n

  • Providers are expected to come into compliance with any waived requirements prior to the end of the emergency period. 
  • n

  • CMS has approved specific waivers & modifications only to the extent that the provider in question has been affected by the disaster or emergency. 
  • n

  • Waivers or modifications under section 1135 of the SSA may be retroactive to the beginning of the emergency period (or to any subsequent date). 
  • n

  • 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). 
  • n

  • Visits are considered the same as in-person visits and are paid at the same rate as regular, in-person visits. 
  • n

  • 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. 
  • n

n

Other Take Homes: 

n

    n

  • All services should be documented/recorded and stored in the EHR to support medical necessity. 
  • n

  • Services must support actual code descriptions. Document what you do, code what you document. 
  • n

  • Check with your current payers to verify specific telehealth/telemedicine requirements. 
  • n

  • Consider researching various intake platforms that will help assist with service communications/ requirements. 
  • n

  • Video & phone calls must be saved by recorded or written documentation in the EHR. 
  • n

  • None of the listed services in this article are billable by clinical staff. 
  • n

  • Time spent with the patient should be documented in all encounters. 
  • n

  • 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. 
  • n

n

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 

Happy National Doctor’s Day!

Happy National Doctor’s Day!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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