COVID-19 Telehealth & Regulatory Changes For RHCs
- Major telehealth restrictions lifted
- New telehealth billing codes introduced
- New telehealth Evaluation & Mangement codes introduced
Major Telehealth Restrictions Lifted
On 3/25/2020, the United States Senate passed a deal on Phase 3 of the COVID-19 legislation that greatly expanded Medicare telehealth services to RHCs.
Before the Coronavirus pandemic, telehealth was only available for rural Medicare beneficiaries and required Medicare patients to physically go to an “originating site,” greatly reducing the convenience of telehealth.
As of now, both of these requirements are lifted, enabling RHCs to serve as the distant site, and providing RHCs with new billing codes to be paid out on or after the Claim Submission Start Dates.
Payments for telehealth visits will not be the all-inclusive rate, however, CMS will create a specific payment mechanism for RHCs and FQHCs based on the average payments under the physician fee schedule.
In an effort to minimize exposure to COVID-19, $275 million in additional funding was authorized for HRSA to support rural hospitals and critical access hospitals (CAHs.) Section 3212 reauthorizes HRSA grant programs that promote telehealth technology use for health care delivery, education and health information services.
New Telehealth Billing Codes
- The following services must be performed by a physician, nurse practitioner, or physician assistant
- These services are only allowed when provided to an established patient
- Up to 3 encounters are allowed every 30 days
- Codes should not be billed if the telephonic encounter originates from a related evaluation and management (E/M) service provided within the preceding 7 days, nor if it leads to an E/M service provided within the subsequent 24 hours
- Services may be provided regardless of the Medicaid member’s location
- The codes should be billed under the GP number
Telehealth Evaluation & Management (E/M) Codes
- Services billed under benefit expansion should be billed with a GT modifier and a 02 Place of Service (telehealth) under the RHCs GP Number
- When rendered by a physician, nurse practitioner, or physician assistant, E/M services in the range of Current Procedural Terminology (CPT) codes 99202- 99204 and 99212-99214 may be provided regardless of the Medicaid member’s location.
- All aspects of the SCDHHS telemedicine policy continue to apply, except for the following:
- Requirements related to the referring site are waived, and services may be provided without regard to the member’s location.
- Requirements that a certified or licensed professional be present at the referring site are waived
- The audio and visual components of the interaction must include sufficient quality and/or resolution for the provider to effectively deliver the care being administered. Otherwise, any specific technology requirements are waived