How to Make Sure Your Practice Achieves Telemedicine Compliance

Telehealth is on the rise. Here’s what you need to know to keep pace.

It seemed like science fiction not long ago, but telemedicine (or telehealth)—real-time, two-way communication between physicians and distant patients—is poised to reshape U.S. healthcare delivery, especially in rural and other underserved areas.

Granted, according to a 2017 study, 82% of consumers “are still largely unaware of how to access telehealth or whether their insurer will cover it.” But 55% of providers are “investing in telehealth to improve health outcomes.” Experts expect a 30% to more than 40% growth in telemedicine in coming years. Increasingly, you’ll need to ensure compliance with telemedicine regulations  as you do the guidelines for in-person patient visits.

Demand for telemedicine will only increase in the coming years, thanks to both expanding cellular connectivity and broadband internet in rural areas and recent and current telehealth legislation, including certain provisions in the Bipartisan Budget Act of 2018. Senator Brian Schatz, a longtime champion of federal telemedicine regulations, told the National Law Review the Act’s passage marks “the most significant [telehealth] changes ever made to Medicare law.” And in 2017, 34 states passed telehealth legislation—more evidence telemedicine is a rapidly growing practice area few providers can afford to ignore.

Because our mission at MDCodePro is helping you achieve maximum compliance and optimal reimbursement for your work, here’s a brief look at regulatory issues with telemedicine you need to know about in order to make it a productive and profitable part of your practice.

Making Sense of the What, Where, and Who of Telemedicine

CMS telemedicine regulations identify which services qualify for Medicare reimbursement, where they must be performed, and which providers may do so.

  • Eligible services involve live audio and video.

Telemedicine-ComplianceWith the exception of certain demonstration programs in Alaska and Hawaii, only live, interactive audio-video communication between providers and patients are eligible for Medicare reimbursement.

Formerly, “store-and-forward” services (transmitting data to physicians via secure email for later review) were not eligible for reimbursement. But as of January 1, 2018, CMS began reimbursing remote patient monitoring (RPM) services under CPT® code 99091. (New codes are being developed CPT is developing new codes that will describe RPM more accurately.)

  • Eligible services begin at a qualified originating site.

Where is your patient located when he or she starts to receive the telehealth service you’re providing? Your answer determines the service’s originating site. Medicare will reimburse services from an originating site located outside a Metropolitan Statistical Area (MSA), as defined by the Census Bureau, or in a rural Health Professional Shortage Area (HPSA), where the Health Resources and Services Administration has identified provider shortages.

Originating sites meeting telemedicine compliance standards include physicians’ and practitioners’ offices, acute care and Critical Access Hospitals (CAHs), Rural Health Clinics and Federally Qualified Health Centers, hospital- or CAH-based renal dialysis centers, skilled nursing facilities, and community mental health centers. Until recently, a patient’s home could not count as an originating site; however, under the Bipartisan Budget Act, Medicare will now reimburse some services provided to ESRD dialysis patients and stroke patients in their homes.

  • Eligible services are performed by qualified healthcare providers.

If you are a physician, physician assistant, nurse practitioner, clinical nurse specialist, nurse-midwife, certified registered nurse anesthetist, clinical psychologist, clinical social worker, or registered dietician or nutrition professional, you may be reimbursed for eligible telemedicine services you provide.

Use MDCodePro to Code E/M Visits in Compliance with Telemedicine Regulations

At MDCodePro, we focus on coding evaluation and management (E/M) services because those services are the ones the majority of most practitioners most often provide. While telemedicine changes delivery methods, it doesn’t change an E/M visit’s basic elements.

“As long as you perform and document the elements of history, exam and decision-making (or time spent counseling),” Bill Dacey writes for Physicians Practice, “and document them the same as you would as if you were there—and meet the basic conditions of a telemedicine visit—then you have a billable evaluation and management visit.”

The coding methodology presented in our easy-to-understand video lecture series and at work in our simple-to-use code generator can help you achieve telemedicine compliance in your telemedicine coding, just as it helps you correctly and optimally code in-person office or hospital visits. Fill out this online form today and we will contact you to share how MDCodePro can help.

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