Age of Telehealth: Documentation and Billing

The COVID-19 pandemic has exponentially expanded adoption of Telehealth prompting the population to progressively become accustomed to the convenience of virtual care.  The skyrocketing volume of Telehealth visits as well as CMS extending various Telehealth PHE waivers and easing restrictions in PFS 2022 has encouraged providers and public/private payers to quickly embrace Telehealth.  With the level of Telehealth service requirements and billing for services primarily based on medical decision-making and time, a technology-driven solution such as RevCDI-led coding from Reventics empowers physicians with continuous chart-specific feedback in near real-time for complete documentation of Telehealth encounters to ensure coding accuracy and optimize reimbursement.  

Documenting Telehealth Services 

Provider documentation plays an indispensable role in coding and reporting Telehealth services.  With delivery of care based mostly on patient communication, all aspects of visit such as date of service, platform used, recordings of audio/video communication, diagnosis, treatment plan, etc., must be documented according to the latest guidelines. 

Challenges 

• Rapid expansion of Telehealth and regulatory waivers are forcing physicians unfamiliar with Telehealth to embrace it and find it challenging to learn and consistently apply rules to accurately document services. 
• Frequent uncoordinated changes in payer rules and documentation guidelines make it a demanding task for providers, coders, and billing staff to continuously familiarize themselves with requirements. 
• Addition of new visit codes, laboratory testing codes, and diagnosis Z codes add to the administrative burden. 
• Medicare Telehealth services carry unique HCPCS and CPT codes that vary based on patient-provider relationship. 
• Payers varying reporting rules leads to misinterpretation of guidelines and difficulty with clarifying CPT, HCPCS, or POS codes and modifiers. 
• Telehealth services are not always covered by private or public payers and payment parity for approved services is variable as well. 
• EHR systems not integrating well with physician platforms to provide Telehealth Services complicating workflow records. 

Billing Telehealth Services 

While Medicare covers a long list of eligible CPT codes, most private payers are billed for Telehealth Services using E&M CPT codes 99201-05, 99211-15 along with a GT or 95 modifier, indicating the services were delivered via Telecommunication. 

Guidelines 

• Private payers sometimes prefer Telehealth specific time-based codes 99421 – 99423, although this varies based on the State and payer (needs confirmation from payer). 
• E&M CPT code and a 95 modifier is usually used to bill Telehealth Services to commercial insurance companies (needs confirmation from payer). 
• Telehealth Services must be billed using E&M code with Place of Service code along with a GT or 95 modifier, those billed without POS code will be denied by Medicare and other payers, though whether they accept the 02 or other POS codes varies. 
• Facility fee is billed by local healthcare facilities hosting the patient using HCPCS code Q3014 for Telehealth services delivered at an originating site with the provider sitting at another site. 
• Certain providers charge a convenience fee of $30 to $75 per visit.

Patient Centered 

Powered by digital technology, Telehealth has multiple tools in its arsenal for both patients and providers to augment patient care while making healthcare accessible to rural population as well as people with limited time, transport, and mobility.  Telehealth provides access to medical specialists and improves coordination of care between patient and medical teams, while also supporting patients with self-management of their health.  It is less time consuming for both patients and providers allowing more time for review of previous summaries, to thoroughly answer questions, review test results, refill prescriptions, schedule appointments, etc.  Telehealth facilitates patients to consult with PCPs or seek alternative care before accessing ED services, thereby preventing low-acuity ED visit and overcrowding.  

Telehealth helps to ensure appropriate post-hospitalization care and wellness through scheduled follow-up visits, routine monitoring, management of postoperative issues, etc., in a timely manner preventing unnecessary readmissions.  It is convenient for maintenance-related visits, for instance, providers can virtually check-in on patients with chronic hypertension to ensure compliance with treatment plans as well as prescribe maintenance medications.  Unlike curbside telephone consults, new-age Telehealth Services are delivered via the patient’s computer/smartphone as well as at originating sites, usually a physician’s office or hospital, with readily accessible telecommunication systems to enhance patient experience and care quality. 

Implementing Telehealth 

With more than half of the hospitals in the United States now conducting Telehealth Programs, Physician Practices are fast following suit, with multiple Regional Telehealth Resource Centers established to assist with implementation. 

Tips 

• Determine the type of Telehealth Service to offer and its utilization in the office. 
• Identify primary group of patients within the practice who may benefit from Telehealth Services, for example, discharge follow ups or other groups of patients. 
• Decide the technology to use, for example, live audio/video feeds, store-and-forward technique, or remote patient monitoring. 
• With only few States in the US enforcing Telehealth Legislation and many yet to join the ranks, clear understanding of legislation and Medicare regulations for Telehealth reimbursements is essential before implementation. 
• Think beyond COVID-19 PHE before choosing the technology to streamline delivery of care, documentation, and billing of Telehealth Services.
• Always contact the local Telehealth Resource Center for Telehealth billing queries.

How Reventics Helps 

Billing for Telehealth Services is tricky with reimbursement polices still forming, frequently changing, and varying from payer to payer.  Providers can overcome these challenges by employing a technology-driven platform to accurately document precise data and maximize allowable reimbursement.  RevCDI-led coding from Reventics focuses on all aspects of clinical documentation improvement and computer-assisted coding with continuous chart-specific feedback in near real-time to increase coding and billing accuracy optimizing revenue.