TeleHealth Update for COVID 19

By
Mark Painter
-

As we continue to see an increased response to COVID 19 with closures, social distancing, quarantines, recommendations to cancel elective surgeries and the associated fear, it is clear that Practices are going to have to find innovative solutions to providing healthcare.  Health of patients, staff and doctors should be of primary concern.  Financial health of the practice will also be impacted.  The extent of these impacts to each community will vary and preparations need to be made.

We are recommending that for each practice you immediately take the following actions:

  • Check with your Mal-practice carrier to determine if and how well you are covered by your current policy.
  • Check the telehealth with your top payers both commercial and Medicare Advantage plans. This can be researched on the payer website, found in your contract or by contacting your payer.
    • Ask if the payer has coverage for telehealth services.
    • Ask what co-payments and payments are allowed under contracts to allow you to notify patients of policies .
    • Ask what requirements and limitations surround telehealth services.
  • Review your financial policies and information release policies to determine if they include telehealth a service release as mentioned in our previous article .  If not update these policies. 
  • Update your patient portal. 
    • If your patient portal allows, update your financial and information release policies and message patients to access the patient portal to print and sign the new forms.  Encourage patients to contact you through the portal for medical needs. 
    • If your patient portal will not allow you to update your forms and procedures nor will it accommodate HIPAA compliant messaging, you will need to explore options to either update the portal or find another means to communicate electronically with the patient. 
  • Determine what your physical capabilities are and what they will be with a timeline.  Most telehealth service coverage is based on interaction with the patient via synchronous audio and visual connection. HIPAA rules will remain in affect but may have some accommodations during the COVID crisis.  Your best efforts to comply with HIPAA must be demonstrated.  Currently tools like Skype and Google chat are not HIPAA compliant.  The service providers will not sign BAAs.  You will need to find an appropriate method to communicate with the patient during a billable encounter.   We recommend that you first check with your EMR vendor to see what options are available.  If the EMR vendor cannot adequately accommodate your needs, there are alternatives.  Please contact us directly with questions, we will be glad to assist.  
  • Develop messaging for your patients on your website and with appropriate signs within the office to include:
    • Current office policies for COVID 19.  Encourage social distancing and assure patients that you have established appropriate cleaning protocols. 
    • Medicare patients:
      • Can be offered and encouraged to initiate visits via telephone or through the portal.   Messaging should be developed to encourage patients to call and cancel appointments if they feel uncomfortable or to comply with state and local directives.  Patients should be told that many of their health needs can be addressed during this time of crisis via telephone or through your web portal.  Patients will need to be told that services provided over the phone or via the internet may be billable and subject to co-payments and deductibles similar to other services that are provided in person.  
    • Patients with private payer coverage (including Medicare Advantage plans) offering telehealth coverage:
      • Can be offered and encouraged to initiate visits via telephone or through the portal.   Messaging should be developed to encourage patients to call and cancel appointments if they feel uncomfortable or to comply with state and local directives.  Patients should be told that many of their health needs can be addressed during this time of crisis via telephone or through your web portal.  Patients may be encouraged to contact the office or insurance plan for information regarding co-payments and deductibles. 
    • Patients with private payers with no telehealth benefits:
      • Can be offered and encouraged to initiate visits via telephone or through the portal.   Messaging should be developed to encourage patients to call and cancel appointments if they feel uncomfortable or to comply with state and local directives.  Patients should be told that many of their health needs can be addressed during this time of crisis via telephone or through your web portal.  Patients in this category will also need to be told that their payers do not offer telehealth benefits.  Therefore, services will be provided on a fee for service basis.  Develop and communicate policies and pricing for these services.  (pricing should not appear inflated and should reflect compassionate care and access concerns.)  This may include a requirement for the patient to sign a form indicating their understanding of the direct bill process and service for the date (modified ABN).  The patient may elect to attempt to collect from the payer for these services.  
    • Patients with Private payers with unclear telehealth benefits:
      • Can be offered and encouraged to initiate visits via telephone or through the portal.   Messaging should be developed to encourage patients to call and cancel appointments if they feel uncomfortable or to comply with state and local directives.  Patients should be told that many of their health needs can be addressed during this time of crisis via telephone or through your web portal.  Patients in this category will also need to be told that their payers are not clear on their coverage for telehealth benefits.  Therefore, services will be provided on a fee for service basis.  The office will ask the patient to sign a document for each service indicating that the service will not be billed to your insurance and is solely the responsibility of the patient.  Develop and communicate policies and pricing for these services.  (pricing should not appear inflated and should reflect compassionate care and access concerns.)  NOTE: Under HIPAA patients have a right to pay directly for services rendered.  If the payment is made in full and not charged to the insurance company the patient will need to sign a release form to allow release of the medical record for that visit to the insurance company. 
  • Train and Update your staff appropriate to their positions to provide appropriate and consistent messaging to patients with regard to telehealth, rescheduling and COVID 19 protocols. 
  • Monitor State and Local bulletins regarding travel restrictions, elective surgical procedures and health care needs. 
  • Monitor Medicare bulletins for emergency declarations in your surrounding areas.  These declarations will likely allow payment for TeleHealth services provided through HIPAA complaint audio-visual sources to a patient regardless of location.  Patients will need to able to give consent to treat and be billed for service payments and co-payments and need to be alerted and agree to TeleHealth services.
  • Establish a team empowered to react to changes for Telehealth and to changing work requirements and develop internal communication pathways and contacts to keep your staff informed and up to date. 
Previous articleTelehealth Changes with COVID–19
Next articleTeleHealth/TeleMedicine Update 3-17-20
Mark Painter
Mark N. Painter is a managing Partner of PRS Consulting, LLC, the CEO of PRS, LLC and the Vice President of Coding and Reimbursement Information for Physician Reimbursement Systems, Inc. (PRS). Since co-founding PRS in 1989, Mr. Painter has served as the primary coding resource for the PRS products including Hotlines, Coding Manuals and quick reference tools, the Internet based application codingtoday.com and seminars. He has lectured to a variety of groups concerned with health care reimbursement. Mr. Painter's extensive knowledge of physician reimbursement issues has allowed him to assist insurance companies, physicians and their staff members, legal counsel, actuaries, Specialty Societies and consultants on a daily basis. He has serves has an expert to legal counsel, bio device companies and pharmaceuticals. He was a co-chair of the Colorado Clean Claims Task Force, a committee of nationally known industry experts charged with the development of single payment edit database for the state. Mr. Painter is a CPMA. Mr. Painter received his B.A. from Grinnell College at Grinnell, Iowa.

RELATED ARTICLESMORE FROM AUTHOR