While telemedicine has always been a convenient way to provide healthcare, the Coronavirus outbreak has accelerated the need for practices to implement a telemedicine solution. Telemedicine offers an opportunity for both remote screening and treatment of Coronavirus cases, as well as an effort to flatten the curve and continue to deliver great care to your patients in general.
Engaging in telemedicine and setting up the infrastructure around it will look different for every practice, but we wanted to provide you with a resource to help your practice move forward. We compiled these most frequently asked questions about telemedicine and COVID-19 to help you navigate what might be a new journey for your practice.
This resource is only provided as a guide and should not be considered legal advice. Telemedicine policy is convoluted due to state and federal laws that vary on several factors. For that reason, your local Telehealth Resource Center is your best resource to get answers for your specific situation.
Please keep in mind that events are evolving. We’ll keep this page updated with new information as it becomes available.
My practice wants to start providing telemedicine. Do our providers need a special certification to get started?
Your providers do not need a special certification to begin offering telemedicine to your patients. You should keep in mind that both the Centers for Medicare & Medicaid Services (CMS), as well as state law, govern which types of providers are considered eligible to provide and be reimbursed for telemedicine services. However, CMS has waived requirements that specify the types of providers that may bill for telemedicine services. Physical therapists, occupational therapists, and speech language pathologists are now considered eligible.
Of course, eligible providers always need to be practicing within the scope of their license. Even though telemedicine is virtual, it’s still local by law: the provider needs to be licensed in the state where a patient is located, even if they’re not meeting in person. CMS has temporarily waived Medicare and Medicaid requirements that providers be licensed in the state where they are providing services, but state requirements still apply.
Some states have temporarily waived certain licensure requirements to help combat COVID-19. To find out what licensure requirements have been waived in each state, check out the site for the Federation of State Medical Boards (FSMB).
Can patients self-pay for telemedicine?
Yes, patients can self-pay for all types of telemedicine encounters. Often patients are willing to pay out-of-pocket for the convenience that telemedicine offers.
Can I get reimbursed for telemedicine through private insurance? What billing codes do I use?
Some insurance companies recognize the value of telemedicine and pay for it, whereas others haven’t embraced it yet. To combat this problem, many states have laws that require private insurance companies to reimburse to the same extent as in-person care for services provided. You’ll want to check whether your state has such a law, and what the law covers — for example, whether real-time video is required for the encounter. These laws vary.
Private insurance companies can also opt to expand their coverage without state action and many have done so, especially since the Coronavirus outbreak.
As for billing for real-time video visits, most private insurance companies advise billing under the appropriate evaluative and management CPT code as if it was an office visit. Some companies require appending a modifier and identifying a place of service, although many are temporarily relaxing these requirements during the COVID-19 outbreak. You should check with your insurers to see what they cover and any coding requirements.
Note on secure messaging: Physicians use CPT codes 99421-99423, as applicable, and qualified health professionals use 98970-98972. Read the CPT manual guidelines to understand requirements, but some basic rules are:
- The communication must be initiated by an established patient.
- How much time you bill for (the range is from 5 to 21 or more minutes) is based on the cumulative time you spent evaluating the patient over a 7-day period.
- The communication must be documented in the patient’s medical record.
Can I get reimbursed for telemedicine through Medicare? What billing codes do I use?
Medicare will reimburse for video visits (they define these as “Medicare telehealth visits”). In the regulation, it is complicated for several reasons, including the mandate that these visits may be reimbursed only on a limited basis: when an established patient receiving the service is in a designated rural area and when they leave their home and go to a clinic, hospital, or certain other types of medical facilities for the service.
However, these rules have been waived effective March 6 and through the duration of the Coronavirus crisis. Medicare will make payments for “Medicare telehealth visits” furnished to patients in any healthcare facility and in their home. Additionally, providers can receive reimbursement even if they do not have an “established patient” relationship.
Providers bill using the telehealth codes provided in the Physician Fee Schedule (generally, this is as if the service has been furnished in person—Medicare pays the same amount). On March 30, 2020, CMS announced that clinicians should use modifier 95 on the claim. Also, clinicians can use the place of service code “11” (instead of “02”), which is the same code as if the patient had been seen face-to-face.
Note on secure messaging: Generally, Medicare will reimburse for evaluating patients over messaging in the following ways.
Virtual check-in services:
- Brief (5-10 minutes) discussion of a clinical matter (G2012) with a patient without using video (can be telephone, secure messaging, etc.).
- Remote evaluation of recorded video and/or images (G2010) submitted by an established patient (also known as “store and forward”). Providers must follow up with the patient within 24 business hours.
- Note: Virtual check-in services were previously limited to established patients, but now providers can perform virtual check-in services to both new and established patients. Keep in mind that the discussion cannot originate from a related evaluation service provided within the last 7 days, nor can it lead to another evaluation/management service or procedure within the next 24 hours or soonest available appointment.
- Online assessment service via secure messaging for an established patient (99421-99423, G2061-G2063). The same guidelines mentioned above under private insurance apply here as well.
Can I get reimbursed for telemedicine through Medicaid?
Telemedicine is covered by Medicaid in most states—you’ll want to look into your state’s Medicaid program to determine the status.
If I want to bill payers for the telemedicine services provided, will the patient have out-of-pocket costs?
This will depend on the patient’s coverage. For Medicare, generally speaking, coinsurance and deductible applies to these services. However, during the Coronavirus outbreak, the HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.
For private insurance, it depends on the specific health plan. However, many insurance companies are also changing their rules to accommodate the Coronavirus crisis. For example, Aetna announced it will temporarily offer zero copay for in-network synchronous telemedicine visits nationally for any reason for all commercial plans. Others such as Blue Cross Blue Shield of California and Cigna have announced similar expansions of coverage. Local governments are also taking action here. On Saturday, March 14, Governor Cuomo announced that the New York State Department of Financial Services will require insurance companies to waive copays for telehealth visits.
What are the requirements to document the clinical evaluation provided by telemedicine in order to bill successfully?
The documentation for a telemedicine visit should cover the matters that the provider determines in their medical judgment are necessary to the advice and/or treatment provided and should be consistent with documentation for any other similar office visit.
Note on secure messaging: You’ll also want to note the method of communication, the cumulative time spent on the patient’s concern, and whether you recommended the patient be seen.
Do I need to obtain my patient’s consent to specifically provide a telemedicine service? If yes, is there a specific way that I need to do it?
This is largely mandated by state law and can also depend on the payer. You can find information specific to your state here.
Under the various state laws, you can usually choose to obtain written or verbal consent, and the consent should be documented in the patient’s medical record.
Generally speaking, these laws state that whether in the visit or beforehand, the patient should be notified about the limitations of the technology and any risks attendant with not seeing the patient in person. For the states that mandate consent, you can usually find more resources on your regional Telehealth Resource Center and on your state’s medical board websites.
Whether this is required also varies by state law, but before the encounter, you should make the patient aware of the cost (if self-pay), or that they will be responsible for any out-of-pocket costs (if covered by insurance).
Note on secure messaging: CMS requires that providers obtain verbal consent for virtual check-ins and e-visits. Providers only need to obtain consent once annually—it can apply to all visits within the year.
How does telemedicine work with guardians of patients for pediatric practices? Are there special rules to follow?
The same consents that providers obtain to provide in-person treatment to minors are generally sufficient, so long as they also include the guardian’s acknowledgment of the limitations of technology and consent to telehealth, as described above.
Do I need a special malpractice rider to perform telemedicine via secure messaging or video visit?
Usually not. Most malpractice carriers cover telehealth so long as it is performed in accordance with state law, medical board guidelines, and applicable standards of practice. However, physicians should check with their insurance carriers to be sure, and if possible, to obtain information about any exclusions or special requirements.
During the Coronavirus outbreak, can providers issue prescriptions to new patients without ever having seen them in person?
While a prescription for a controlled substance issued by telemedicine must generally be predicated on an in-person medical evaluation, there is an exception because we’re currently in a public health emergency. During this time, DEA-registered practitioners may issue prescriptions for controlled substances to patients for whom they have not conducted an in-person medical evaluation, provided all of the following conditions are met:
- The prescription is issued for a legitimate medical purpose by a practitioner acting in the usual course of his/her professional practice
- The telemedicine communication is conducted using a real-time video visit
- The practitioner is acting in accordance with applicable Federal and State law.
With Klara, your practice can get started with powerful, multi-channel telemedicine. Real-time video visits and asynchronous text messaging work together in one seamless conversation so you can provide patients with excellent care, no matter where they are.