COVID-19 Telehealth and Reimbursement
During the COVID-19 crisis, sensible telehealth and reimbursement policies are essential to allow physicians and practices to continue providing preventive, acute, and chronic care for their patients, to provide care in a manner that keeps our health care workforce safe, and to protect physician practice viability.
Here's what you need to know to best utilize telehealth in your practice:
HIPAA relaxed at the federal level: The Health and Human Services agency has relaxed HIPAA regulations for physicians using telehealth to treat their patients. This change allows for the use of video chat applications (FaceTime, Skype, etc.) to provide telehealth services.
Office of the Insurance Commissioner OKs the use of non-HIPAA compliant platforms including telephone: The OIC has issued an order requiring all state-regulated carriers to permit and reimburse for care provided over non-HIPAA compliant platforms – including video chat applications and the telephone.
Governor Inslee's proclamation requires payment parity: The proclamation implements SB 5385 – requiring telemedicine services to be paid for at parity with face-to-face services – immediately.
Medicaid also paying at parity: Medicaid, including MCOs and FFS, are both paying for telehealth – including services administered over the telephone – at parity.
Medicare relaxing telehealth requirements: The Centers for Medicare & Medicaid Services has expanded telehealth services and waived certain telemedicine regulations for Medicare beneficiaries during the 2019 Novel Coronavirus pandemic.
Adopting Telehealth as COVID-19 Response
Telemedicine allows patients to continue to receive the care they need to manage chronic conditions or minor illness from the safety of their own home. During this public health crisis, allowing patients to receive health care in their homes is safer for the patient as well as the practitioner and their staff.
Larger practices and systems currently using telehealth technology are working to scale up those services as demand for COVID-19 testing increases. Smaller and midsized physician practices may want to consider adopting telehealth, which is recommended by the Centers for Disease Control and Prevention to help mitigate the impact and prevent the spread of COVID-19. Telehealth can:
- Enable people to access care and initial screenings from their home.
- Minimize the demands on in-person primary care offices, urgent care centers, and emergency departments.
- Minimize the use of personal protective equipment like gloves and masks.
- Reduce the risk of exposure to patients and medical care teams.
- Ensure that treatment is available for high-need patients.
Setting up telehealth at your practice
The Centers for Medicare & Medicaid Services has released a comprehensive toolkit for general practitioners that contains links to reliable sources of information on telehealth and telemedicine, which will reduce the amount of time providers spend searching for answers and increase their time with patients. Many of these links will help physicians learn about the general concept of telehealth, choose telemedicine vendors, initiate a telemedicine program, monitor patients remotely, and develop documentation tools. Additionally, the information contained within each toolkit will also outline temporary virtual services that could be used to treat patients during this specific period of time. Download the Telehealth Toolkit for General Practitioners. (March 23, 2020)
The Health Care Authority has purchased a limited number of licenses for Zoom, a video conferencing technology that can help physicians provide virtual care. The HCA will distribute the licenses free of charge to physicians and providers who have a meaningful need and who don't already have access to telehealth technology, including physicians in smaller practices. Visit the HCA website to apply. We believe this offer by the HCA is a direct result of our advocacy on behalf of our small practice physicians, and we thank the agency for making these available. (March 20, 2020)
Comcast announces comprehensive COVID-19 response. For physicians or providers with patients who lack or have limited internet access, Comcast's new temporary policies may help facilitate access to telehealth services. Learn more. (March 13, 2020)
COVID-19 Telehealth Reimbursement
The WSMA is advocating for payment parity for delivering telemedicine services. Learn more about our telehealth advocacy efforts and find breaking telehealth developments below.
Gov. Inslee's proclamation on payment parity
On March 25, Washington state Gov. Jay Inslee issued a proclamation that implemented Senate Bill 5385 immediately. Among other provisions, SB 5385 requires carriers to pay for telemedicine services at parity with face-to-face visits. This change applies to all state-regulated plans. However, this change is not applicable to certain self-insured/ERISA plans that are not regulated by the state. Gov. Inslee's proclamation will expire at midnight on April 24, 2020. For the order to be renewed, the governor will need approval from legislative leadership.
The Washington State Health Care Authority (HCA) has released guidance to help address your questions on billing Apple Health (Medicaid) fee-for-service programs, as well as managed care organizations, for services including telehealth – Apple Health (Medicaid) clinical policy and billing for COVID-19. (March 27, 2020) The guidance provides CPT codes.
Note : The FAQ specifies that telemedicine needs to be delivered via HIPAA-compliant communications; however, the federal government announced that it has relaxed HIPAA rules for health care providers using telehealth in response to COVID-19. See "Telehealth Exceptions" section below.
HCA also offers the following guidance – Apple Health (Medicaid) coverage for telemedicine services. (March 14, 2020)
For more information about the Health Care Authority's response to the coronavirus outbreak, review the agency's information about novel coronavirus (COVID-19) page.
Federal Medicaid telehealth guidance can be found here and an updated Medicaid & CHIP COVID-19 FAQ can be found here. (March 18, 2020)
As a result of WSMA and other physician association advocacy, on the evening of March 30, 2020, the Centers for Medicare and Medicaid Services (CMS) released an interim final rule (and fact sheet) temporarily expanding the list of covered telehealth services and providing regulatory waivers to help hospitals and physician practices respond to the 2019 Novel Coronavirus pandemic. The new services and waivers are intended to help facilitate telehealth visits with Medicare beneficiaries, including permitting physicians to provide certain services by telephone to new or established patients using CPT codes 98966-98968; 99441-99443.
For the duration of the public health emergency, telehealth services will be reimbursed at the same rate as a face-to-face visit. To implement this change, CMS instructs physicians to bill for Medicare telehealth services to report the POS code that would have been reported had the service been furnished in person and use modifier 95. These changes are effective retroactively – starting March 1, 2020.
The Washington State Office of the Insurance Commissioner issued an emergency order on March 5, 2020, indicating that a carrier cannot deny telehealth reimbursement for use of a non-traditionally HIPAA-compliant platform.
The Washington State Department of Labor and Industries has announced a temporary telehealth policy. This policy will allow physicians and health care providers to treat injured workers from their homes with the goal of supporting the containment of COVID-19. Read the policy in full. (March 10, 2020)
AMA released special coding advice related to COVID-19, including guidance for telehealth services for all patients. The resource outlines coding scenarios designed to help health care professionals apply best coding practices.
COVID-19 Telehealth Exceptions
The Health and Human Services Office for Civil Rights (OCR) announced that it is relaxing HIPAA rules for health care providers using telehealth in response to COVID-19. This change is effective immediately. According to OCR, the agency "…will waive potential HIPAA penalties for good faith use of telehealth during the nationwide public health emergency due to COVID-19." Under this notice:
A covered health care provider that wants to use audio or video communication technology to provide telehealth to patients during the COVID-19 nationwide public health emergency can use any non-public facing remote communication product that is available to communicate with patients. This includes Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype, to provide telehealth without risk that OCR might seek to impose a penalty for noncompliance with the HIPAA Rules related to the good faith provision of telehealth during the COVID-19 nationwide public health emergency.
Full information and guidance can be found here.
Prescribing controlled substances
Under the Secretary of Health and Human Services' public health emergency declaration, DEA-registered practitioners may now issue prescriptions for controlled substances to patients for whom they have not conducted an in-person medical evaluation, provided certain conditions are met. Read the DEA announcement. (March 16, 2020)
General COVID-19 Coding and Reimbursement
Coding for novel 2019 coronavirus and COVID-19
Medicaid (Apple Health)
For more information about the Washington State Health Care Authority's response to the coronavirus outbreak, review the agency's information about novel coronavirus (COVID-19) page.
The Centers for Medicare & Medicaid Services posted an update to its Frequently Asked Questions (FAQs) on the Medicaid.gov website to aid state Medicaid and Children's Health Insurance Program (CHIP) agencies in their response to the 2019 Novel Coronavirus (COVID-19) outbreak. (March 18, 2020)
Medicare has created this website to answer COVID-19-related questions.
The Centers for Medicare & Medicaid Services issued FAQs addressing Medicare payment for laboratory tests and other services related to the 2019-Novel Coronavirus (COVID-19). (March 6, 2020)
The OIC waives copays, deductibles, and preauthorizations for COVID-19 testing and requires insurers that are regulated by the OIC must: allow a one-time early refill for prescription drugs; suspend prior authorization requirements for treatment or testing of COVID-19; and, if an insurer does not have enough medical providers in its network to provide testing and treatment for COVID-19, it must allow enrollees to be treated by another provider within a reasonable distance at no additional cost. Read the announcement and the OIC emergency order. (March 5, 2020)
The Trump administration announced that a number of major insurance carriers (Blue Cross Blue Shield, Anthem, Humana, and UnitedHealthcare) had agreed to provide coverage for telemedicine services, as well as waiving copays and extending coverage, for COVID-19 patients. (March 10, 2020)
America's Health Insurance Plans has compiled this list of individual insurance carriers' response to the COVID-19 outbreak. While not all carriers operate in Washington state, the list details which are offering reimbursement and waivers for COVID-19-related treatment. (March 6, 2020)
Quality reporting programs
The Centers for Medicare & Medicaid Services is implementing policy exceptions and extensions for physicians, hospitals, and facilities participating in quality reporting programs, including MIPS and ACOs. Read the press release. (March 22, 2020)
Under the Secretary of Health and Human Services public health emergency declaration, DEA-registered practitioners may now issue prescriptions for controlled substances to patients for whom they have not conducted an in-person medical evaluation, provided certain conditions are met. Read the DEA announcement. (March 16, 2020)
The Washington State Telehealth Collaborative provides a forum for collaboration and sharing of resources to help increase public awareness of telehealth. The collaborative offers a clinician's FAQ guide to telehealth and a list of telehealth resources.
Let the WSMA policy department help
Please reach out to firstname.lastname@example.org with any questions on any if the information provided on this page or on using telehealth as a COVID-19 response.