Optimize new telehealth regulations to serve your patients and accurately code new COVID-19 CPTs and diagnoses
As our healthcare system strains to bear the brunt of COVID-19, providers have been granted new flexibility to use telehealth services via common internet video platforms. Additionally, new coding options are available to accurately reflect diagnosis and the services rendered during the health emergency.
Expanding telehealth during the COVID-19 crisis is necessary to increase the breadth and reach of healthcare services, protect front-line staff to possible infectious exposure and help people comply with stay-at-home orders. Therefore, on March 17, the Office for Civil Rights (OCR) and the U.S. Department of Health and Human Services (HHS) announced that providers could begin to see patients via everyday video communication technologies during the COVID-19 health emergency without fear of HIPAA violations. Although this is welcome news, it does not mean that providers can have an ‘anything goes’ mindset. There are many important factors to recognize during telehealth visits under the emergency regulations – here are our top 6 to know.
1. Not all technologies are compliant for COVID-19 telehealth
The announcement says that the OCR will use their discretion when investigating HIPAA compliance and that some platforms such as Twitter and Facebook Live are not appropriate for medical communications. Instead, it recommends systems such as Skype, Apple Facetime and Google Hangouts used in private (or semi-private) settings. Business Associate Agreements are not required during the crisis. If health information is intercepted or hacked during telehealth interactions, OCR will use its discretion and will not pursue penalties for HIPAA breaches.
2. The relaxed regulations apply to all health visits, not just COVID-19 related visits
Providers are expected to use their discretion as to which patients can be evaluated and treated during a telehealth visit. In addition to COVID-19, providers may also diagnose and treat other conditions as well as perform check-in visits for services such as prescription reviews.
3. Reasonable safeguards need to be in place to protect patient PHI
Patient privacy must still be protected when possible. In addition to using non-public technology, reasonable steps to protect confidentiality still need to be followed, which include conducting visits as privately as possible and using the minimum necessary disclosure rule. Billing staff working from home are expected to protect patient information by taking steps such as:
- Working on private networks
- Safeguarding work materials, so they are not inadvertently seen by household members
- Shredding papers with PHI
- Avoiding saving billing information to private computers
4. There are new COVID-19 telehealth CPTs
Temporary CPTs have been added to the CMS telehealth list. Many (but not all) frequency limitations (for example, those pertaining to nursing facility visits) are temporarily suspended. Modifier 95 is still necessary to indicate telehealth services. In most cases, place of service (POS) is determined as if the visit is in-person; for example, if the visit usually would have taken place in an office, the office POS code applies.
Categories of temporary additions to telehealth CPT coding include:
- Therapeutic exercises
- Gait training therapy
- PT evaluations
- OT evaluations
- Initial observation care
- Initial hospital care
- Emergency department visits
- Initial nursing facility care
- Home visits for new and established patients
5. Documentation rules still apply
Even though the appointment is through a temporary telehealth medium, thorough notes of the evaluation must always be recorded. Many organizations may prefer to use time rather than medical decision-making for E/M coding because of the inherent limitations of telehealth. If coding with time, be sure to note the beginning and end of every visit in the patient record.
6. Check payer and MAC websites before using temporary codes
As with all other medical billing scenarios, each payer may have its own coding conventions. It is critical to confirm that the correct code is used to avoid denials and delays in payment – even in this time of crisis.
In addition to CPTs, there are new diagnosis codes for COVID-19
The World Health Organization has added two emergency ICD-10 codes for COVID-19:
- U07.1 – confirmed positive diagnosis through lab testing
- U07.2 – diagnosis of COVID-19 where lab confirmation is inconclusive or not available
The AMA also suggests several diagnosis codes which pertain to COVID-19:
- Z03.818 COVID-19 rule-out after possible exposure
- Z20.828 exposure to a person with COVID-19
- Z11.59 asymptomatic, no known exposure, results unknown or negative
Also, the AMA has added emergency COVID-19 in-office and outside lab testing codes (friendly reminder – don’t forget to include specimen collection codes if you are performing the collection in your office). Specimen collection and lab work performed by an organization can be recorded with telehealth visits on the same claim.
Information pertaining to COVID-19 telehealth rules and coding will evolve over the course of the pandemic. Check-in frequently with your medical specialty association, the AMA or a trusted coding professional like MDCodePro to stay abreast of the latest developments.
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