Virginia Premier continues to be committed to the safety of you, our providers, patients and communities that we serve together. We want to support your heroic efforts to address the COVID-19 outbreak.
Since COVID-19 developments are occurring quickly, we’re providing this update on telehealth:
- What is Telehealth?
Telehealth includes the use of videoconferencing, the internet, store-and forwarding imaging, and other telecommunications technologies to support virtual patient health care.
HIPAA Requirements during the coronavirus (COVID-19) pandemic:
During the COVID-19 national emergency and effective immediately, the Office of Civil Rights at the Department of Health and Human Services “will not impose penalties for noncompliance with the regulatory requirements under the HIPAA Rules against covered health care providers in connection with the good faith provision of telehealth during the COVID-19 nationwide public health emergency.”
How these Telehealth changes impact you:
During this state of emergency, Virginia Premier will cover telehealth benefits related to urgent and non-urgent office visits for all of our health plans. Providers will be paid at their contracted rate and all cost sharing will be waived for members through August 31, 2020.
Delivery of Services via Telehealth for Medicaid, Medicare, and Individual and Family Health Plans (New Guidelines):
When delivering services via telehealth, providers are required to adhere to the same standards of clinical practice and record keeping that apply to other covered services.
- This applies to telehealth provided for any reason and does not have to be related to diagnosis and treatment of coronavirus (COVID-19). The full notice and related guidance on acceptable applications for Medicaid (DMAS) can be found here.
- CMS maintains a list of services that are normally furnished in-person that may be furnished via Medicare telehealth. This list is available here:
DMAS and CMS will reimburse for Medicare/Medicaid-covered services delivered via telehealth where the following conditions are met:
- Providers must assure the same rights to confidentiality and security as provided in face-to-face services. Providers must ensure the patient’s informed consent to the use of telehealth and advise members of any relevant privacy considerations.
- The requirement that services delivered via telehealth (real-time, two-way communications) must use both audio and visual connection is being waived. Both DMAS and CMS are allowing the use of audio connections, in addition to audio-visual connections.
- Both DMAS and CMS are waiving the requirement that provider staff must be with the patient at the originating site in order to bill DMAS for the originating site facility fee. These “tele-presenters” should not be required for payment of the originating site fee.
- Click here to view Frequently asked Provider Questions for Telehealth provided by CMS
- Providers should submit claims for telehealth services using the appropriate CPT or HCPCS code for the professional service delivered.
- Providers are asked to update their systems and procedures as soon as possible to enable the use of modifiers (GT or GQ) and telehealth POS (02) when billing for services delivered via telehealth.
- Providers using telehealth POS (02) and modifiers for telehealth services covered under the prior policy shall continue to use the modifier GT (via interactive audio and video telecommunications system) or GQ (via synchronous telecommunications system), or POS code (02) when billing for services delivered via telehealth.
- Both services delivered via telehealth and billed using telehealth modifiers, and services delivered via telehealth and billed without modifiers will be reimbursed at the same rate as the analogous service provided face-to-face.
- Providers should maintain appropriate documentation to support medical necessity for the service delivery model chosen, as well as to support medical necessity for the ongoing delivery of the service through that model of care.
Home as Originating Site
During the coronavirus (COVID-19) pandemic, DMAS is relaxing the requirement that provider staff must be with the patient at the originating site in order to bill DMAS for the originating site facility fee.
- This is particularly important for members, who are quarantined, those who are diagnosed with or demonstrating symptoms of coronavirus (COVID-19), or those who are at high risk of serious illness from coronavirus (COVID-19).
- Clinicians should use clinical judgment when determining the appropriate use of home as the originating site.
- No originating site fee will be paid for telehealth in the home.
Telehealth in the Delivery of Behavioral Health Services
DMAS will allow for telehealth, including telephonic delivery of all behavioral health services with several exceptions.
Services that will be allowed using telehealth include:
- Care coordination, case management and peer services
- Service Needs Assessments, including the Comprehensive Needs Assessment; the IACCT assessment in Mental Health; the Multi-Dimensional Assessment in ARTS; and all treatment planning activities
- Outpatient Psychiatric Services
- Community Mental Health and Rehabilitation Services
- Addiction Recovery and Treatment Services
- The per diem rates for therapeutic group homes, psychiatric residential treatment facilities, and inpatient psychiatric hospitalization will not be billable through telehealth; however, within these services, activities including assessments, therapies (individual, group, family), care coordination, team meetings, and treatment planning are allowable via telehealth
- Behavioral health providers delivering services via telehealth, including telephonic communications, should simply bill and submit a claim as they normally would in their regular practice.
- The Place of Service (POS) that the provider usually bills should remain the same and no modifiers will be necessary in order to minimize systems errors during this critical time.
- Providers should maintain appropriate documentation to indicate the mode of delivery and to support medical necessity for the ongoing delivery of the service through that model of care. Providers should move to systems changes to allow Place of Service Codes (02) to reflect telehealth delivery, as this will be required at a future date.
Early Intervention Services
- Early Intervention (EI) providers are permitted to use telehealth or remote care delivery for all ongoing services to include developmental services, physical therapy, occupational therapy, and speech-language pathology to include monitoring of successful program and instructional implementation, coaching, treatment teaming and service plan development.
- Assessments for new cases can be done on a limited basis in person or using synchronous telehealth technologies at the discretion of the local service provider with the child and family’s consent.
Telehealth for Long-term Care Nursing Home Facilities
Effective March 30, CMS is issuing an electronic toolkit regarding telehealth and telemedicine for Long Term Care Nursing Home Facilities. CMS has broadened access to Medicare telehealth services so that beneficiaries can receive a wider range of services from their doctors without having to travel to a healthcare facility.
Most of the information in this toolkit is directed toward providers, who may want to establish a permanent telemedicine program, but there is information here that will help in the temporary deployment of a telemedicine program as well. There are specific documents identified that will be useful in choosing telemedicine vendors, equipment, and software, initiating a telemedicine program, monitoring patients remotely, and developing documentation tools. There is also information that will be useful for providers who intend to care for patients through electronic virtual services that may be temporarily used during the COVID-19 pandemic.
Billing for Telehealth
Telehealth Codes for Medicaid (DMAS)
To find a full list of Medicaid codes visit https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.
Code | Definition | Provider Type/Specialty |
|---|---|---|
99201 – 99205 99211-99215 | Initial and subsequent E&M office visit or other outpatient visit | MD: 020/000 NP: 023/000 FQHC: 052/000 RHC: 053/000 Health Dept.: 051/000 |
99221-99223 99231-99233 | Initial and subsequent hospital care | MD: 020/000 NP: 023/000 QHC: 052/000 RHC: 053/000 Health Dept.: 051/000 |
Q3014 | Telemedicine Facility Fee | MD: 020/000 NP: 023/000 QHC: 052/000 RHC: 053/000 Health Dept.: 051/000 |
99304-99306 99307-99310 | Initial and subsequent physician nursing home care | MD: 020/000 NP: 023/000 QHC: 052/000 RHC: 053/000 Health Dept.: 051/000 |
99354-99355 99356-99357 | Prolonged service office Prolonged service inpatient | MD: 020/000 NP: 023/000 QHC: 052/000 RHC: 053/000 Health Dept.: 051/000 |
CMS Telehealth Code Guidelines
Type of Service | What is the Service? | HCPCS/CPT Code | Patient Relationship with Provider |
|---|---|---|---|
Medicare Telehealth Visits | A visit with a provider that uses telecommunication systems between a provider and a patient | Common Telehealth services include:
| For New* or established patients.
*To the extent of the 1135 waiver requires an established relationship, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency.
|
Virtual Check-in | A brief (5 to 10 minutes) check-in with your practitioner via telephone or other telecommunications device to decide whether an office visit or other service is needed. A more remote evaluation of recorded video and/or images submitted by an established patient |
| For established patients |
E-Visits | A communication between a patient and their provider through an online patient portal. |
| For established patients |
Additional Provider Telehealth Resources:
- CMS Telehealth Toolkit for General Practitioners
- Telehealth Toolkit for End-Stage Renal Disease Providers
- Medical Society of Virginia
- Virginia Department of Health
- CMS Telehealth Education Booklet
Tips to assist you ensure a positive member telehealth video experience:
Remember, telehealth visits will typically take 10 to 15 minutes. Here are a few tips to ensure a positive patient experience:- Set-up the appointment with the patient and be on time.
- Think about where you are conducting the visit -from home or the office? Make sure the background is appropriate, because it will matter to the patient.
- Build a rapport with the patient immediately
- Remember, most people who are not familiar with telehealth technology will look down at the phone rather than look you in the eye. Try to work with the patient and put them at ease.
- Watch body language and reaction to care recommendations
- Refrain from doing EHR documentation during the video visit. Give your undivided attention to the patient.
