The Changing Landscape of Telemedicine Billing, Payment, and Reimbursements (since COVID-19)

Since the COVID-19 pandemic began, the use of telemedicine has greatly accelerated. Whether patients stay at home due to government mandates or due to concerns for their own safety, providers use telemedicine more than ever before as a way to provide care to patients without requiring an office visit. This has increased the availability and accessibility of care, but the increased use of telehealth services has made it more difficult for providers to receive payment for their services.

What Are the Changes in Telemedicine Billing, Reimbursements, and Payments Since COVID-19?

Since telehealth practice was comparatively rare before COVID-19, reimbursement policies were inconsistent, including different regulations from Medicare, state governments, and private insurers. Although telehealth practice was growing prior to COVID-19 due to increased demand for access, telehealth formed a very small percentage of provider services before March 2020. With the spread of COVID-19, telemedicine grew exponentially. Many providers began treating at least some of their patients remotely, and telemedicine growth led to policy changes and revised billing practices.

Some of these changes include:

• Permitting patients to be treated at home
• Waiving out-of-pocket costs for telemedicine visits
• Expanding telemedicine to urban residents
• Changes to payment for audio-only visits
• Waiving of the requirement for licensure in the state where the medical service is provided
• Not enforcing HIPAA software requirements
• Expansion of types of care and types of providers eligible for telemedicine
• Restrictions on opioid prescriptions for telehealth visits lifted
• Full coverage for COVID-19 tests and diagnosis

These changes are mostly temporary and vary by insurer and by state. However, some elements of telehealth practice and policy may remain after the pandemic is over.

Code Requirements for Telehealth & Telemedicine Services

Whether providers bill for telehealth services during or after the pandemic, new billing codes for telehealth and telemedicine services are here to stay, and it’s important to use them correctly to be reimbursed. Here are a few of the most common codes for telehealth billing:

• 99201-99205 — New patient, office or outpatient visit
• 99211-99215 — Established patient, office or outpatient
• 99411-99443 — Audio only/Phone consultation. These codes vary according to the time spent on the call.
• 99421-99423 — New online telehealth/E-Visit codes. An E-Visit must be initiated by the patient.
• Modifier 95 for commercial payers – This code is used by most commercial payers for synchronous telehealth services – in other words, the service should closely match the service that would be provided during a face-to-face visit.
• CR Modifier for Medicare — This code is used for Medicare Part B and describes an emergency or a catastrophe. Medicare does not require use of the CR modifier for telehealth claims. The CR modifier is only effective for the duration of the public health emergency (i.e. COVID-19).
• G2061-G2063 — Online assessment and management of an established patient by a qualified healthcare professional (non-physician) for up to seven days. The code varies by time spent with the patient online.
• 98970-98972 – Non-physician e-Visit codes for commercial payers

Changes Affecting Reimbursement and Funding

Before the pandemic, telehealth regulations limited providers’ ability to provide telehealth services. Once COVID-19 hastened the emergence of telehealth, government agencies and insurance companies acted quickly to increase access.

To permit more providers to offer telehealth services, the Centers for Medicare and Medicaid Services (CMS) increased telehealth reimbursement rates from $14–$41 to $46–$110 per visit. The U.S. Department of Health and Human Services (HHS) awarded $15 million to programs for increasing telehealth during the pandemic. In addition, private insurers such as Aetna, Anthem, Cigna, Humana, and UnitedHealthcare changed their telehealth reimbursement rates to match their face-to-face reimbursement rates. Many government and private insurers also now allow remote evaluation of many medical conditions.

Changes Affecting Administration of Telehealth Services 

In March of 2020, CMS allowed doctors to provide telehealth services from any location (they could previously only conduct telehealth visits while at a doctor’s office or hospital) and permitted patients to receive services at any location (telehealth visits had previously been restricted to patients in rural locations). CMS also expanded the range of permitted telehealth services.

Health Insurance Portability and Accountability Act of 1996 (HIPAA) guidelines, which were enacted to protect patient privacy, were relaxed during COVID-19 to permit the use of video chat applications such as Facetime, Zoom, and Skype. They were also expanded to allow patients and physicians to use their own devices rather than purchasing approved equipment for telehealth services.

In addition, providers may temporarily provide telehealth services in another state without being required to be licensed in the state where they provide that service, which increases access to telehealth for many patients. The types of practice that are permitted to provide telehealth have also been expanded to include speech language pathologists, physical therapists, occupational therapists, and other providers.

At this point, it is still unclear which billing and reimbursement policies enacted during COVID-19 are temporary and which will become permanent. The expansion of telehealth increased access to medical care for many patients, especially those on Medicare. However, since the growth in telehealth services happened so quickly, it’s important to evaluate both its failures and successes.

“In light of our new experience with telehealth during this pandemic, CMS is reviewing the temporary changes we made,” says Seema Verma, Administrator for the Centers for Medicare and Medicaid Services (CMS), “and assessing which of these flexibilities should be made permanent through regulatory action.”

Manage and Mitigate Risks in Telemedicine

Although the lack of telehealth restrictions has increased access for many patients, it also holds risks. If providers are not required to be licensed in the state where they provide services, it could compromise patient safety.

Under typical circumstances, providers must undergo a rigorous credentialing process in every state in which they practice. This protects patients by effectively preventing healthcare entities from hiring providers whose credentials are not current or valid or who have been excluded from practice due to healthcare fraud or other crimes. Without these safeguards, patients may unknowingly risk their safety, security, or finances when they visit with a new and unknown provider.

Healthcare organizations can avoid these risks by hiring a credentials verification organization such as Verisys that can provide primary source screening, license verification, and continuous monitoring of providers’ credentials. Verisys verifies against databases and licensing boards throughout the nation, so even during public health emergencies like COVID-19, Verisys can ensure that your providers are qualified and competent to practice. The real-time information Verisys provides can keep your patients and your practice safe despite the changing landscape.
 

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