Telehealth billing guide highlights complexities of use

The Center for Connected Health Policy has published a 21-page guide intended to help providers with telehealth-based Medicare and Medicaid reimbursements.

The guide offers clarification for billing for remote patient monitoring, synchronous (real-time) asynchronous (store-and-forward) telehealth services and billing for virtual healthcare services, as well as mobile health services.

It focuses primarily on fee-for-service Medicare and an example of one Medicaid program, California’s Medi-Cal, as a starting point—the report also notes the complexity and sometimes nebulous terminology like “distant sites” and “originating sites”.

For example, Medi-Cal designates a “distant site” as a site where a health care provider who provides health care services is located while providing these services via a telecommunications system. The distant site for purposes of telehealth can be different from the administrative location.

This allows the practitioner to be in a location suitable to telehealth encounters, but not necessarily in a clinic or facility themselves, according to the California Department of Health Care Services.

For Medicare “originating sites,” beneficiaries need to be at a site outside a metropolitan statistical area or within a defined eligible location, with a few exceptions, while a Medi-Cal beneficiary can be geographically anywhere.

The report offers eight different cases in which the billing for telehealth services can vary based on the type of healthcare plan and care received, for example a 35-year-old man on Medi-Cal who has consented to e-consultation.

In addition, the CCHP provides guidance on additional ways providers can benefit from the use of telehealth components in bundled management of care scenarios, namely through chronic care management and transitional care management.

The report concluded that until telehealth is considered a mode of care as opposed to a separate type of service, what can and cannot be billed and reimbursed would vary depending on state rules and regulations.

Patient demographics are also likely to affect billing workflows and choices, and the report notes there are other policies to consider that could impact telehealth billing, as well as opportunities that may not be readily apparent because services are not called “telehealth” but utilize the technology.

Telehealth technology could offer multiple benefits to patients and providers alike–a recent American Hospital Association report on workforce strategic planning trends says the technology is well-positioned to help health systems combat professional staffing shortages.

Asynchronous virtual visits are helping reduce the burdens on primary care providers at Prisma Health, while also enabling easier access, convenience and speed to care for patients. In another case study this week, we showed the tangible work-life benefits and financial ROI enjoyed by one solo practice’s shift toward telehealth consults.

The guide notes that while telehealth is a promising technology, its value is tempered by complications that arise due to reimbursement policies that vary from payer to payer–for example, policies that apply to a Medicare beneficiary are different than those that apply to a Medicaid enrollee.

“Before embarking on these services, consider the front-end education for your staff,” said CCHP expert, “so that patients are provided with educational materials, as CMS suggests, so that the cost of the back-end, billing folks interacting with patients, do not negate the benefits of utilizing these services.”

Nathan Eddy is a healthcare and technology freelancer based in Berlin.
Email the writer: [email protected]
Twitter: @dropdeaded209


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