By Catherine Lightfoot, CPA, CHBC, Director of Healthcare at EEPB
In the early days of the COVID-19 pandemic, innovative Telehealth strategies took off by necessity, as patients felt more comfortable visiting with their primary care physician from the safety of their own homes. The remote delivery of medical services continues to be an opportunity to build revenue and retain those patients who still opt for Telemedicine as a preferred mode. According to a study by McKinsey (May 2021), 88 percent of consumers said that they had used Telehealth services at some point since the pandemic began.
Relevant legislation
Last month, Congress passed House Bill 117, Omnibus, which includes extending Telehealth. It appears that this extension is so MedPac and HHS OIG can study and analyze the associated benefits, costs, and risks and report back to Congress on whether or not the expansion of Telehealth under the COVID-19 Pandemic Health Emergency (PHE) should be permanent. Also, based on certain language in the bill, the new extension date goes to September 13, 2022, when this too will expire or a decision will be made to extend or not or modified to extend it permanently. Therefore, the special rules related to Telehealth being under the PHE still apply and will be in effect until at least mid-September.
On March 15th, President Biden signed into law H.R. 2471, the Consolidated Appropriations Act, 2022, which provides $12.6 billion in IRS funding and extends Telehealth services covered by health savings accounts for the months beginning after March 31, 2022, and before January 1, 2023. The extension removes Telehealth services from the requirement to satisfy annual deductibles under high-deductible health plans. Note that this provision expired on December 31, 2021.
All of this makes me believe the “new normal” for healthcare professionals and patients alike warrant a solid look at incorporating a Telehealth program into your practice as a long-term strategy.
Considerations for a successful Telehealth program
Alongside these exciting changes, there are also some changes that bring more tedium to the way telehealth is coded, e.g. for the purposes of Medicare reimbursement. I am sure you are aware that phone encounters are billed under different codes than virtual e-visits. And that’s just the beginning. Understanding the full ramifications of these rulings is key to accurately reporting the type of Telemedicine services rendered in order to ensure proper payment is received.
Telehealth rules change from state to state. So what do you do when physicians cross state lines? How do you handle providers who now only want to work virtually? These and many other new policies will need to be given the necessary consideration to set your practice up for a positive outcome.
Telehealth codes are presenting a new level of complexity and compliance in terms of billing and coding. This can really upset an otherwise smooth-running back-office process. Now maybe the time to consider outsourcing Telehealth coding to a specialist, who must stay up-to-date on the latest coding information for your medical specialty and can also assist with your overall revenue cycle management.
Conclusion
As new COVID-19 variants emerge and are projected to do so indefinitely, the future of remote medical consultation will be prominent in the delivery of care model—for both patient and physician. In addition to being aware of the latest Telehealth legislation, it pays to invest in learning the applicable codes, either by providing employee training opportunities or by forming a relationship with a third party to take Telehealth coding off your plate entirely.