BUILDING TELEHEALTH CAPACITY

for BEHAVIORAL HEALTH

Telehealth Billing & Reimbursement

April 29, 2020

Northwest Mental Health Technology Transfer Center

Our Role:

Provide training and technical assistance (TA) in evidence-based practices (EBP) to behavioral health

and primary care providers, and school and social service staff whose work has the potential to improve

behavioral health outcomes for individuals with or at risk of developing serious mental illness in

SAMHSA’s Region 10 (Alaska, Idaho, Oregon, and Washington).

Our Goals:

• Ensure availability and delivery of free, publicly-available training and TA to Region 10 providers.

• Heighten awareness, knowledge, and skills of the workforce addressing the needs of individuals with mental illness.

• Accelerate adoption and implementation of mental health-related EBPs across Region 10.

• Foster alliances among culturally diverse mental health providers, policy makers, family members, and

clients.

www.mhttcnetwork.org/northwest

The MHTTC uses affirming language to promote the

promises of recovery by advancing evidence-based and

culturally informed practices.

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There will NOT be certificates or CEUs for this series.

Slides & resources WILL be posted after the session

After today’s session Please complete the evaluation survey (LINK):

Today’s Presenters

• Gail Kreiger, BSN

Section Manager

Medicaid Compliance Review and Analytics

Medicaid Program Operations and Integrity

• Catherine Britain

Executive Director, Telehealth Alliance of Oregon

Founding Board Member, Northwest Regional

Telehealth Resource Center

Today’s Panelists

• Brad Felker, MD VA Puget Sound Health Care System Professor, University of Washington Dept of Psychiatry & Behavioral Sciences

• Marc Avery, MD Principal Consultant, Health Management Associates Clinical Professor of Psychiatry, University of Washington

• Melody McKee, MS, SUDP Program Director, Behavioral Health Training, Workforce and Policy Innovation Center, Behavioral Health Institute

• Cara Towle MSN RN MA Associate Director, Telepsychiatry University of Washington

Behavioral Health Institute (BHI)

Training, Workforce and Policy Innovation Center

The Behavioral Health Institute (BHI) Is a Center of Excellence where

innovation, research and clinical practice come together to improve

mental health and addiction treatment. The BHI established initial

priority programs which include:

• Improving care for youth and young adults with early psychosis

• Behavioral Health Urgent Care Walk in Clinic

• Expanded Digital and Telehealth Services

• Behavioral Health Training, Workforce and Policy Innovation

Center

BUILDING TELEHEALTH CAPACITY

for BEHAVIORAL HEALTH

TELEHEALTH BILLING &

REIMBURSEMENT

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SESSION #3 OBJECTIVES

> Review Medicaid billing and reimbursement for telehealth during the Covid19 public health emergency

> Review Medicare billing and reimbursement for telehealth during the Covid19 public health emergency

> Review private payer billing and reimbursement for telehealth during the Covid19 public health emergency

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DISCLAIMER

> Any information provided in today’s talk is not to be regarded as legal advice. Today’s talk is purely for informational purposes.

> Always consult with legal counsel.

> Presentation is based on information available as of 4/25/2020.

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MEDICAID – APPLE HEALTH PAYS FOR TELEHEALTH

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OVERVIEW OF TELEHEALTH/TELEMEDICINE

In the healthcare community the words telehealth and telemedicine are often used interchangeably.

• For WA Medicaid:

• Telemedicine per state law is defined as: the delivery of health care services through the use of HIPAA compliant interactive audio and video technology, permitting real-time communication between the patient at the originating site and the provider, for the purpose of diagnosis, consultation, or treatment.

• Telehealth considered: an umbrella term that includes Telemedicine as well as other temporary policies, including technologies that may not be HIPAA compliant and may not be conducted through interactive audio-video exchange. Telehealth policies were implemented to expand the type of telecommunications that can be used to provide assessment, diagnosis, intervention, consultation, supervision and information in lieu of an in-person visit.

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TELEHEALTH/TELEMEDICINE (“TELE”)

POLICIES HCA is:

•Adhering to it’s current telemedicine policies, but added new telehealth policies that will be effective through the pandemic

•Instructing providers to bill using the CPT or HCPC code that would be billed if the visit was in-person

•Paying the same amount for a “tele” visit as it would for an in-person visit

•Offering additional codes to be used, as required:

•for telephone calls with new or established patients: 99441 - 99443

•for on-line digital exchange vis patient portal: 99421 - 99423

•for a brief virtual check-in telephone call, or texting, with an established patient: G2012

•for “tele” contacts made outside of M-F 8-5; and on weekends: 99050 & 99051

Refer to the BHFAQ for specifics on the policy, how to bill and who may bill.

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TELEHEALTH/TELEMEDICINE TIPS Key points to know:

• Read the entire BHFAQ some parts are general information ( PARTs V-VI) applicable to every provider/biller

• Just like if you are billing for a BH in-person visit, know which benefit you are using and what you are billing for: o Is it a SERI encounter service that is reported/billed to an MCO, BHSO or ASO?

Then bill according to PART l of the BHFAQ o Is it a service being billed to ProviderOne, you are an approved AI/AN provider and

billing according to Part II of the FFS Mental Health Billing Guide? Then bill according to PART ll of the BHFAQ

o Is it a service being billed to ProviderOne or a MCO and defined in Part I of the FFS MH Billing Guide?

Then bill according to PART lll of the BHFAQ

• Any service provided that meets the definition of telemedicine is billed using POS “02”. The use of a modifier is addressed in each specific PART of the BHFAQ

• Any service being rendered using another telehealth technology use the POS specific to where the client is.... not the provider, and bill using the CR modifier if your EHR will support it

• Although the MCOs and ASOs are to follow these “tele” policies, they may have different billing requirements so please follow any instructions they may provide

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HCA’S TELEHEALTH/TELEMEDICINE POLICIES

HCA has dedicated a section of its COVID-19 website https://www.hca.wa.gov/information-about-novel-coronavirus-covid-19 to behavior health providers.

On this page you will find telehealth/ telemedicine Q&As and Webinars, including specifically: A telemedicine/ telehealth brief https://www.hca.wa.gov/assets/billers-and-providers/telehealth-brief-for-COVID-03-2020.pdf

Behavior health FAQ https://www.hca.wa.gov/assets/billers-and-providers/behavioral-health-policy-and-billing-COVID-19.pdf &

OTP FAQ https://www.hca.wa.gov/assets/program/opioid-treatment-program-faq.pdf

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WHO (ELSE) PAYS FOR TELEHEALTH?

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• Medicaid (Managed care organizations, fee for service)

• Medicare (including Medicare Advantage Plans)

• Private Payers

• ERISA (self-insured company plans)

• Patient self pay

WHO PAYS FOR TELEHEALTH?

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MEDICARE

• Medicare beneficiaries are eligible for telehealth services if:

• They are presented in an originating site located in a CMS defined rural area.

• In addition: • The type of originating site must be approved by CMS;

• The type of provider must be approved by CMS; and

• The type of service must be approved by CMS

• The services must be provided using two-way audio and video telecommunications that are HIPAA compliant

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ELIGIBLE PROVIDERS

• Physicians

• Nurse practitioners

• Physician assistants

• Clinical nurse specialists

• Clinical psychologists (CP)

• Clinical social workers (CSWs) (NOTE: CPs and CSWs cannot bill Medicare for psychiatric diagnostic interview examinations with medical services or medical evaluation and management services. They cannot bill or get paid for Current Procedural Terminology (CPT) codes 90792, 90833, 90836, and 90838).

• FQHCs/RHCs (during the COVID emergency period only)

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MEDICARE EXPANSION

• Beginning in 2019 CMS made some major changes to the services it will reimburse when delivered via telehealth: Expansion of originating site

– Renal Dialysis Facilities*

– Homes of beneficiaries with ESRD receiving

home dialysis*

– Mobile Stroke Unit *

– Beneficiaries home when receiving SUD and related mental health services*

• *Geographic limitations do not apply

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MEDICARE – COVID RULES

• Medicare will pay for services delivered to their beneficiaries in any health care facility and in their homes. These visits are considered the same as in-person visits and are paid at the same rate as regular, in-person visits.

• Medicare has expanded the list of eligible services. (Easy to use list: https://www.cms.gov/files/document/covid-19-physicians-and-practitioners.pdf)

• Medicare has added FQHCs and RHCs to the list of eligible providers for the emergency period only

• Medicare will allow any mobile computing device that have audio and video capabilities to be used in the provision of services (not public facing apps). The HHS Office of Civil Rights may waive penalties for HIPAA violation

• Medicare will not enforce the established relationship requirement

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MEDICARE – COVID RULES

• A subsequent inpatient visit can be furnished via telehealth without the limitation that the telehealth visit is once every three days (CPT codes 99231-99233);

• A subsequent skilled nursing facility visit can be furnished via telehealth, without the limitation that the telehealth visit is once every 30 days (CPT codes 99307-99310)

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• Originating national sites allowed $26.65 Per Medicare Economic Index (MEI) defined by Social Security Act annually

• Submit Q3014 without modifiers

• Submit appropriate place of service (POS)

MEDICARE FACILITY FEE – ORIGINATING SITE

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MEDICARE FACILITY FEE – COVID RULES

• The originating site facility fee cannot be paid to the home.

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• Per CMS: Innately not face-to-face = not “telehealth”

• Virtual Check-Ins (HCPCS G2012)

– Established patients

– No E/M in prior 7 days or subsequent 24 hours/“soonest available”

– 5-10 minutes of discussion

– During COVID clinicians can provide services to both new and established patients.

– During COVID clinicians, including physicians, can now

provide certain services by telephone to their patients

(CPT codes 98966 -98968; 99441-99443)

MEDICARE OTHER TECHNOLOGY-ENABLED

SERVICES

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• E-Visits - Remote Evaluation of Pre-Recorded Data (HCPCS G2010)

– Established patient sends recorded images or videos through a patient portal

– Interpretation and follow-up in 24 hours

– No E/M in prior 7 days or subsequent 24 hours/“soonest available”

– During COVID consults may be provided to a patient beyond the

once per day limitation (CPT codes G0508-G0509).

– During COVID licensed clinical social workers, clinical psychologists,

physical therapists, occupational therapists, and speech language

pathologists can provide e-visits. (HCPCS codes G2061-G2063).

MEDICARE OTHER TECHNOLOGY-ENABLED

SERVICES

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• Interprofessional Consultations (eConsults)

– 6 codes - 5 for consultative physician; 1 for treating or requesting physician or QHP (99446, 99447, 99448, 99449, 99451, 99452

– Telephone, internet, EHR assessment/management

– Verbal and/or written reports required

– Certain limitations on frequency

MEDICARE OTHER TECHNOLOGY-ENABLED

SERVICES

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• Reimbursement from private payers is also dependent on the laws and policies of each state.

• Private payer reimbursement can extend beyond what is in policy or legislation depending on what the payer sees as a valuable service and what the payer and provider are able to negotiate into the contract.

• Private payer legislation/ policy for each state can be found on the CCHP web site at: https://www.cchpca.org/telehealth-policy/current-state-laws-and-reimbursement-policies?jurisdiction=All&category=128&topic=All

PRIVATE PAYERS

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• Many employers fund group health plans for their employees.

• Those plans are regulated by the Employee Retirement Income Security Act (ERISA).

• The plans must be in compliance with state laws. Most parallel laws governing private payers

• Although ERISA does not have a policy on telemedicine, they recognize the value telemedicine can provide to both employers and employees.

• ERISA works with states to encourage the development of telehealth and not impose barriers to its use.

ERISA – SELF-INSURED COMPANY PLANS

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• Patients can choose to pay for a service delivered telemedically themselves if their insurer denies payment

• This occurs especially when the services are direct-to-patient such as virtual urgent care.

• People without insurance and seniors with Medicare are often willing to self-pay in order to get the services they need/want

• Payers are seeing positive data generated by these services and some are offering their own products

PATIENT SELF-PAY

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• Telehealth reimbursement during COVID does not look like it did prior to the pandemic, and it will not necessarily look the same after the pandemic ends.

• Many are hoping that the laws will remain as they are now, but a solid business plan is not built on what we hope will happen.

• Telehealth providers have the remarkable opportunity to show that telehealth can function better in this relaxed regulatory environment by keeping good data for our services during this time.

KEEP IN MIND

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NEVER HESITATE TO ASK FOR HELP

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• For Medicare: • https://www.cms.gov/newsroom/fact-sheets/medicare-

telemedicine-health-care-provider-fact-sheet • https://edit.cms.gov/files/document/medicare-telehealth-

frequently-asked-questions-faqs-31720.pdf • https://www.cms.gov/Medicare/Medicare-General-

Information/Telehealth/Telehealth-Codes • https://www.cms.gov/files/document/covid-19-physicians-and-

practitioners.pdf • https://www.youtube.com/watch?v=bdb9NKtybzo&feature=you

tu.be • https://www.cms.gov/files/document/general-telemedicine-

toolkit.pdf • https://vsee.com/blog/telehealth-billing-covid-19/

RESOURCES

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RESOURCES • For Private Payers and ERISA:

• https://www.governor.wa.gov/sites/default/files/proclamations/20-29%20Coronovirus%20OIC%20%28tmp%29.pdf

• Check with the state Health Authority and/or Washington State Office of the Insurance Commissioner for information

• For General Resources: • https://nrtrc.org/covid-19

• https://www.cchpca.org/

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Thank you! • Contact information

• Catherine Britain, Executive Director

• Telehealth Alliance of Oregon

• csbritain@gmail.com

• 541-910-7366

• www.ortelehealth.org

What we must decide is how we are valuable rather than how valuable we are.

~Edgar Freidenberg

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QUESTIONS & DISCUSSION

Behavioral Health Institute (BHI)

Training, Workforce and Policy Innovation Center

BEHAVIORAL HEALTH TELEHEALTH RESOURCE

For more information including upcoming training

& additional resources:

Visit us online:

https://bhi-telehealthresource.uwmedicine.org/

Email us:

melmckee@uw.edu

Your Feedback is Important:

• Please complete the anonymous evaluation by following the link in the chat box & you’ll get a reminder email also.

• Evaluation data is necessary for continued funding to offer programs

Post-event surveys are

critical to our work!

Your feedback helps us to improve and

develop future programing.

We greatly appreciate your feedback!

Get in Touch with the Northwest MHTTC

Visit us online:

www.mhttcnetwork.org/northwest

Find out about:

• Upcoming trainings

• New online trainings

• Resources and Research Updates

Email us:

northwest@mhttcnetwork.org

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Thank You!