For years, countless studies have affirmed the interest in telehealth by commercial insurance subscribers, but adoption remained low. As of 2019, only 10% of healthcare consumers had used telehealth services. The majority of early adopters were females and patients ages 31 to 40 years old. The 2019 satisfaction rates with such services were also impressive, second only to direct banking, coming in at 851 on a 1,000 point scale.
However, everything has changed due to the COVID-19 pandemic. With the outbreak of COVID-19 and social distancing measures, healthcare providers have rapidly shifted in-person patient visits to virtual appointments. These telehealth services allow physicians to counsel and treat patients at a safe distance and increase the accessibility of crucial healthcare services. With any emerging technology, telehealth presents its own risks.
What Do Relaxed Telehealth Regulations Mean for Billing?
While most adopters of telehealth services were insured by commercial insurance providers, the passage of the Coronavirus Assistance, Relief, and Economic Security (CARES) Act and Section 1135 of the Social Security Act has expanded the virtual services available to Medicare beneficiaries. These measures are considered temporary and are subject to change due to the COVID-19 pandemic.
Healthcare providers can now bill for telehealth services, regardless of zip code, and patients can receive these services from their homes. The Centers for Medicare and Medicaid Services (CMS) has relaxed several requirements for these services, but there are still billing regulations to keep in mind. Providers must only use billing codes approved for telehealth, meet code requirements, and take care to document effectively.
The complete list of Medicare telehealth billing codes can be found on the CMS website. Physicians also need to understand if the service is available via telehealth to new patients or only current patients before seeing new ones virtually. As for patients covered by private insurance policies, the regulations and billing practices will vary by insurance company. To date, 37 states and the District of Columbia have laws mandating reimbursement for telemedicine services. Reimbursable services, provider eligibility, and reimbursement levels vary by state legislation.
Currently, major insurance carriers including Blue Cross Blue Shield, Aetna, Cigna, and United Healthcare cover telemedicine services with policy-dependent reimbursement coverage. Billing requirements for private insurance companies are subject to frequent changes; telehealth platforms with integrated insurance eligibility check for these requirements to help providers stay on top of these updates.
Popular Consumer Applications Bring Accessibility and Risk
In response to COVID-19, the HHS Office for Civil Rights has issued temporary measures to make telehealth services more accessible. HIPAA-covered health care providers may use FaceTime, Facebook Messenger, Google Hangouts, Zoom, and Skype. The Office cautions against using public-facing applications such as Facebook Live, Twitter, and TikTok.
Despite relaxed telehealth guidelines, standard documentation and consent regulations still apply. Applications such as FaceTime and Google Hangouts allow providers to connect with patients, but do not handle documentation, charting, billing, patient communications, or scheduling.
The use of disparate systems increases the risk of human errors such as failing to bill, forgetting to schedule follow-up appointments, entering notes into the wrong patient file, and more. These applications also present security risks (see: Zoom bombing), opening up physicians to lawsuits and state actions. Companies such as Facebook and Google are reluctant to share information about their data storage and destruction policies.
CMS has waived requirements for Business Associate Agreements (BAAs) with vendors. However, obtaining a BAA is still a best practice, as some insurance companies will not reimburse vendors lacking a BAA to take responsibility for data breaches. Furthermore, these public applications have lax identity regulations, putting the onus on physicians to confirm patient identity before beginning any consultation.
Purpose-built applications with embedded security, integration, and compliance protections safeguard physicians from the risk that comes with emerging virtual services. These applications are especially important for medical practice owners who also manage office operations.
At RXNT, we understand how important it is to provide accessible, secure patient services in a remote setting. If you’d like to explore how our telehealth-friendly solutions operate alongside secure video platforms, please reach out for a quick, no-pressure demo.