Use of Telemedicine during the COVID-19 Pandemic
Your clinic is likely already experiencing disruptions and considering alternative ways of seeing and advising patients. Telemedicine, virtual check-ins, remote patient monitoring, and eVisits are services delivered using virtual and other technologies that many healthcare professionals are implementing; in fact, both the CDC and WHO are encouraging people to use of these options, and many regulatory updates have made so visits are more feasible for both clinicians and patients.
Answers to Your Questions about Telemedicine
How do I get started? Click the link for answers to the questions below.
- How do I start setting up telemedicine?
- What platform do I use?
- Do I need to have the patient sign a telemedicine consent form?
- What do I do if the patient is not able to connect? Can I still have an encounter?
How do I conduct a physical exam via Telemedicine? Click the link for a video that answers this question.
How does billing work? Click the link for answers to the questions below.
- How do I bill for a telemedicine visit?
- How do I bill for Medicare patients?
- How do I bill for Medicaid patients?
- How do I bill an e-visit?
- Can I bill for telephone encounters?
Effective March 6, 2020, Medicare will pay for office, hospital, and other visits furnished via telehealth across the country and regardless of the patients location (e.g., home). CMS recently reminded practitioners that they can update their enrollment with their home location, in order to deliver telehealth from their home. Additional information regarding HHS’ enforcement discretion on HIPAA privacy and security is below.
Virtual Check-ins & eVisits
Where an established relationship is present, practitioners offer virtual check-ins and eVisits. Virtual check-ins can be delivered with a broader range of communication methods, such as telephone, audio/video, secure text messaging, email, or use of a patient portal, with the patients consent. Patients can also request an eVisit through a patient portal. Information about coding for various services can be found here: Utilize Telemedicine: How does billing work?
During the COVID-19 national emergency, certain provisions of HIPAA will not be enforced for covered health care providers utilizing telehealth services. This allows clinicians some flexibility to utilize technologies that may not be fully compliant with HIPAA rules. For example, a clinician may use the private video chat functions in common apps, such as Facebook Messenger, Zoom, or Google Hangouts. However, public-facing apps (e.g., Facebook Live, TikTok) are not allowed. Read the full notification of enforcement discretion here.
In addition, the telephone may be used as long as the telephone has "audio and video capabilities that are used for two way, real time interactive communication.” The act does not restrict telehealth to the diagnosis related to the Coronavirus but it does restrict telehealth to services previously covered for telehealth (consultations and office visits). The full list of telehealth services is on CMS’ website.
While Secretary Azar was able to waive certain licensure requirements to allow for Medicare and Medicaid payments to providers who do not have a license within that State, the waiver does not extend to non-Federal programs. As such, some states require physicians to have a medical license in the same state that their patient is located in order to provide virtual healthcare.
Given this long-standing challenge, the Federation of State Medical Board (FSMB) established the Interstate Medical License Compact Commission (IMLCC) to help clinicians practice across state lines. At this time, 29 states, the District of Columbia and the Territory of Guam, have agreed to the compact. Note that twelve (12) state boards issue a special purpose license, telemedicine license or certificate, or license to practice medicine across state lines to allow for the practice of telemedicine.
Even if an out-of-state provider is able to address the licensure and credentialing issues, the practitioner may be considered out-of-network by private payers.
Navigate your State’s Response to COVID-19
Track and compare every state's bills in response to the coronavirus. This resource is available to everyone who needs to better understand. It includes legislation, ranging from health preparedness, to worker compensation and economic injury relief for small businesses to Executive Orders. It is searchable by state and by topic.
OIG Policy Statement Regarding Physicians and Other Practitioners That Reduce or Waive Amounts Owed by Federal Health Care Program Beneficiaries for Telehealth Services During the 2019 Novel Coronavirus (COVID-19) Outbreak (March 17, 2020)