Understand the current requirements, and be aware that they may change
Telehealth has become a topic much talked about during the COVID-19 crisis, providing a socially distant method for seeing patients amid varying states of quarantine throughout the United States.
Many optometrists will know that the Secretary of Health and Human Services (HHS) declared a public health emergency on Jan. 31, due to the crisis. In response, both Medicare and HIPAA released relaxed guidelines for interacting with patients.
As optometrists utilize these services as eligible providers, it’s important to understand where we’re at and be aware of changes to this process in the future.
WHAT QUALIFIES AS A TELEHEALTH SERVICE?
“Medicare telehealth services include office visits, psychotherapy, consultations and certain other medical or health services that are provided by an eligible provider who isn’t at your location using an interactive two-way telecommunications system (like real-time audio and video),” the CMS say on its website at medicare.gov/coverage/telehealth . Medicare telehealth services differ from virtual check-ins and e-visits.
In a notice to Florida Optometric Association members, it was stated as this: “A virtual check-in pays professionals for brief (5-10 min.) communications that mitigate the need for an in-person visit, whereas a visit furnished via Medicare telehealth is treated the same as an in person visit, and can be billed using the code for that service, using place of service 02 to indicate the service was performed via telehealth. An e-visit is when a beneficiary communicates with their doctors through online patient portals. Medicare pays the same amount for telehealth services as it would if the service were furnished in person.”
Virtual check-ins. Check-ins allow patients to talk to their doctor or certain other practitioners, such as nurse practitioners or physician assistants, using a device, such as a phone, integrated audio/video system or captured video image without going to the doctor’s office. The doctor, or other practitioner, responds using a phone, audio/video, secure text messages, email or use of a patient portal.
Requirements for the visit to be billable include such things as the patient must talk to the practitioner, and it must not relate to a medical visit in the last seven days.
E-visits. This service allows patients to talk to their doctor using an online patient portal without going to the doctor’s office. These also require that patients talk to the doctor or other practitioner to start these visits.
WHAT ARE THE PRIVACY CONCERNS WITH TELEHEALTH?
Many have asked questions about HIPAA rules, enforcement and violations. According to HHS’s website: “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.”
If you are utilizing video technology, seeing patients through a window at your own facility or utilizing some other social-distancing protocol on site, these services should not be reported as telehealth services, as that would require the individual physician or professional providing the telehealth service not be at the same location as the beneficiary.
LOOK FOR CHANGES
As we work through the opening of our practices and help patients through their trepidation, it is important to remember that telehealth may still play an important role.
The challenge for all of us will be monitoring the changes in billing and coding as they are made, so that we can utilize telehealth and get paid for it. Look to AOA, your state association, AAO and communication from the insurance plans you participate in for daily updates to be certain you are compliant with new rules and regulations as they are implemented. OM