Updated 3/25/20 -
At Catalyst Consulting, our goal is to support our clients as the healthcare environment changes daily with the Covid-19 emergency. Please feel free to call us with your questions and comments. As this situation is dynamic many practices are adapting their operations, together we are sharing this information so that it might help other clients.
Our largest volume of questions right now is related to telemedicine regulations and billing for those visits. Several helpful links are provided in this post for both federal guidelines as well as Texas-specific guidelines.
We have also received guidance that the reporting of MIPS data has been moved to April 30 versus March 31st.
Just in summary, both the Federal and the Texas Guidelines have waived the HIPAA guidelines to allow Telemedicine visit by methods other than secure services which might be provided in Telemedicine software. Providers are now allowed to use Facetime on a cell phone and Skype to provide a video component to your visit. You are also allowed to conduct telephonic visits as well.
From a billing perspective, if you provide a visit with a billing component, you can bill for a visit with your normal visit CPT codes. If you provide a visit telephonically only, you must bill the visit using the regular Telemedicine visit codes.
However, a number of state organizations have been lobbying congress to change this and allow telephonic visits to be reimbursed at the same regular visit level. None of us knows how the billing process will ultimately turn out, and the major insurance companies are just as overwhelmed with moving their staff to work remotely. As a result, we have not been successful in getting answers, but expect them to follow the Medicare guidelines at this point.
You can begin a new physician-patient relationship during this Emergency period without a face-to-face visit. However, we do not currently have advice on Well Visits via any electronic mode, so we are all waiting for that specific requirement to be communicated.
In Texas, Telemedicine can only be used to treat patients with chronic pain management issues and to prescribe opiates if there is an already established physician-patient relationship.
The links below will give you access to specific information. If you have a state-specific link other than Texas, please share it with us and we will post this for others in your state.
Thank you for looking to Catalyst Consulting for additional information during this crisis.