COVID-19 Resources

COVID-19 and Telemedicine

(Version 2.0; last updated May 7, 2020)

The laws and policies regarding telehealth are state dependent and are rapidly evolving. It is critical to check with your state medical board and your institution for specific guidance. Please review ASH's disclaimer regarding the use of the following information.

Checklist for a telehealth videoconference visit:

  1. Use an allowed video platform by the federal government (currently FaceTime/Skype, or other HIPAA-compliant system) and your institution (which may have stricter guidelines)
  2. State your name and show your ID if on video
  3. Have the patient confirm their identify (generally show ID or ask date of birth)
  4. Ask if anyone else will be present during the telehealth visit and confirm their names and relationships
  5. Get verbal consent for the telehealth (video or phone) visit [See below for key points]
  6. Conduct visit: Physical exam may be based on what is visible: affect, appearance, movement. Patients can participate by showing the location of pain, what movements cause pain, can shine a flashlight to let you look at their throat etc.
  7. Make a plan for follow up or next visit, if applicable

Checklist for documenting a telehealth videoconference visit: (Note: Different states require that specific points be documented. Check with your state medical board or institution for their requirements. The following statement are examples only.)

  1. State that this is a video conference, including state and location of provider(s) and patient, equipment used, reason for a telehealth visit, and all people on the videoconference:
    “I saw Mr. First Last and his wife, Mary via real-time video conference using Zoom HIPAA-protected live interactive audiovisual equipment, to reduce exposure risk during the COVID-19 response. This service was performed from my home in WA and from Mr. Last’s home in CA.”
  2. Confirm that consent was obtained. Use the wording for verbal consent for the visit, especially for the first visit. “The patient verbally consented to the video-visit including that the physical exam may be limited and that a co-pay or other self-pay may be required”
  3. Document content of visit as usual
  4. Time statement to document length of visit:
    “This visit on 3/30/20 was conducted by means of a two-way synchronous video [or audio-only] connection. I spent a total of 30 minutes between 9:00 to 9:30am face-to-face with the patient during this videoconference, with more than 50% of the time spent in counseling and coordination of care about his maintenance therapy for myeloma.”

Key points for verbal consent:

  • This visit will be documented in your medical record, the same as if it were an in-person clinic visit
  • No video, audio or photo recordings will be taken (unless the telehealth portal is integrated with your EHR)
  • Physical exam will be limited but I may document findings I observe
  • As with a clinic visit, you may be billed for the self-pay portion (co-pay, deductible, etc.) of the bill

Notes:

  • Ability to bill depends on where the patient is located during the telehealth visit
  • Billing is identical to an in-person visit but will likely be using time statements
  • Involvement of residents, fellows, APPs is identical

Reimbursement for Audio-Only Telehealth Services During the COVID-19 Public Health Crisis

On April 30, the Centers for Medicare and Medicaid Services (CMS) finalized, on an interim basis and for the duration of the COVID-19 crisis, the following work RVUs and national average payment rates for the telephone - only evaluation and management (E/M) services (CPT codes 99441-99443):

  • 0.48 RVUs for CPT code 99441 - $46 (5-10 minutes of medical discussion)
  • 0.97 RVUs for CPT code 99442 - $76 (11-20 minutes of medical discussion)
  • 1.50 RVUs for CPT code 99443 - $110 (21-30 minutes of medical discussion)

Continue reading for more detail…

On March 30, the Centers for Medicare and Medicaid Services (CMS) released an Interim Final Rule with a number of regulatory changes to help the U.S. healthcare system address the COVID-19 public health crisis. Included in that rule, was information on reimbursement for audio-only telehealth services.

During the COVID-19 crisis, CMS will reimburse for audio-only telehealth for CPT codes 98966 – 98968 and 99441 – 99443. Previously noncovered, these CPT codes will now receive separate payment on an interim basis during the COVID-19 public health crisis.

On April 30, CMS released another Interim Final Rule including sweeping regulatory waivers and rule changes to provide additional flexibility to physicians and patients during the COVID-19 crisis further addressing audio-only telehealth services. In this rule, CMS is establishing new RVUs for the telephone - only evaluation and management (E/M) services (CPT codes 99441-99443) in order to align to the comparable office/outpatient E/M codes, based on the time requirements for the telephone codes and the times assumed for level 2, 3, and 4 office/outpatient E/M codes. Specifically, CMS is crosswalking the physician work RVUs and practice expense inputs for CPT codes 99212, 99213, and 99214 to the telephone only CPT codes 99441, 99442, and 99443 respectively.

References:

Emory University Telehealth Tools

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