Summary of Medicare policies in 2020. Public Health Emergency Interim Final Rules.

Telehealth. More services are covered.

Medicare now pays healthcare providers for more Telehealth services, such as:

• Initial inpatient and nursing facility visits;
• Emergency department visits;
• Initial/subsequent observation services;
• Some physical and occupational therapy, as well as speech-language pathology services.

Other services that can be performed via Telehealth are 

• Advanced Care planning 
• Smoking and tobacco cessation counseling 
• Annual Wellness Visits
• Annual alcohol misuse screening
• Behavioral counseling for alcohol misuse
• Annual depression screening
• behavioral counseling for obesity

The full list can be found here .

But that's not the end of an adventure! 

CMS also expanded the types of health care professionals who can provide telehealth services and now include all of those who are eligible to bill Medicare including physical therapists, occupational therapists, and speech-language pathologists, etc.

More information can be found here.

Also, practitioners may reduce or waive members' cost-share for the services during the crisis.

Medicare also covers 100% for the Office and other outpatient services, including online digital E&M services in cases: 

• The visit results in an order for a COVID-19 test; 
• The visit results in an administration of a COVID-19 test;
• The visit is related to providing the COVID-19 test;
• The purpose of the visit is to determine the need for the COVID-19 test. 

Providers must report CS modifier on the superbills for billing purposes. The modifier is recognized by Medicare to cover the visit at a 100% rate with no cost-sharing.

More information can be found here.

Now for Telehealth, providers use the place of service that they would normally use for the services in case those are performed face-to-face. Modifier 95 to regular procedure codes, which providers normally bill for face-to-face encounters, will indicate the procedure was performed as a Telehealth. Moreover, the Telehealth payment rate is equal to a face-to-face visit rate.

Audio-only real-time interaction 

CMS also allowed certain services to be covered as Telehealth services when performed using audio-only real-time interaction, e.g., psychotherapy. 

For more details visit  https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes

CMS cross-walked the values for CPT codes 99441, 99442, and 99443 (telephonic evaluation and management) to 99212, 99213, and 99214 (regular office visits), respectively.

Telephonic evaluation and management services, CPT codes 99441-99443, were added to the list of Medicare-covered telehealth services.

While code description for telephonic evaluation and management codes 99441 -99443 and 98966 - 98968 refers to an "established patient," during the PHE, the codes are applicable for both new and established patients.

Level Selection for Outpatient, Office E&M Visits When Furnished Via Medicare Telehealth

During the PHE, Telehealth Outpatient/Office Evaluation and Management services (99201-99205, 99211-99215) level selection can be based on medical decision-making (MDM) or time ( total time associated with the E&M on the day of service). 

RPM Services 

Remote Physiologic Monitoring (RPM) Services 

Now, both new and established patients can receive RPM services. Consent can be obtained at the time the services are provided. These services can also be used for physiologic monitoring of patients with acute and/or chronic conditions, furnished under general supervision. For some RPM services, the number of days for data collection was modified.

For more details visit https://www.cms.gov/files/document/covid-medicare-and-medicaid-ifc2.pdf

Communication Technology-Based Services (CTBS)

These services may only be used if they do not originate from a related visit nor result in a visit, including a telehealth one, and can be furnished to both new and established patients. Keep in mind that a consent to receive these services must be obtained annually from the patient, it may be obtained at the same time the service is provided. Also, licensed clinical social workers, clinical psychologists, physical therapists, occupational therapists, and speech-language pathologists may now bill for Communication Technology-Based Services.

Direct Supervision by Interactive Telecommunications Technology 

Direct supervision can now be provided using real-time interactive audio and video technology. This change is limited to cases in which the supervision requirements can be met and do not affect the underlying payment or coverage policies related to the scope of Medicare benefits.

Supervision of Diagnostic Tests by Certain Non-physician Practitioners.

Now nurse practitioners, clinical nurse specialists, physician assistants, and certified nurse-midwives can provide the appropriate level of supervision required for the performance of diagnostic tests. These non-physician practitioners may order, furnish directly and now supervise the performance of diagnostic tests (subject to applicable State law). 

COVID-19 Laboratory Test orders – fewer requirements for better testing.

Any healthcare provider, authorized under State law, can now order COVID-19 diagnostic laboratory tests (including serological and antibody tests). 

Laboratories need to indicate referring/ordering provider's NPI on a claim when a written order is provided. When a test is provided without a provider's written order, the laboratory is required to directly notify the patient on the results. Because the symptoms for influenza, respiratory syncytial virus (RSV), and coronavirus are often the same, concurrent testing for all three viruses is warranted. 

For more information, on Medicare coverage of laboratory tests go to https://wchsb.com/News/WCHNewsItem/69a08fa7-97ed-4859-bcc1-a267dcb560a0?page=1

Pharmacists Providing Services "Incident to" Physician and NPP Services

Pharmacists may now provide services "incident to" and under the appropriate supervision of, the billing physician or non-physician practitioner, if payment for the services is not made under Medicare Part D and the service is provided within the pharmacist's state scope of practice and applicable State law. 

 

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Source: https://www.cms.gov/files/document/mm11805.pdf