1st Healthcare Compliance
May 22, 2020
Sonal Patel, a Health Care Coder and Compliance Consultant for Nexsen Pruet, was recently featured in an article for 1st Healthcare Compliance's magazine, Connect. Sonal answered the most commonly asked questions in regards to her webinar, "Compliance Coding & Billing for Telehealth During COVID-19."
When are these codes good for billing purposes during this pandemic and do you recommend I hold my claims?
According to the April 6, 2020 published Interim Final Rule, the applicability date for these regulations is March 1, 2020. So yes, I hope you have held claims since then because there has been so much confusion due to misinformation, as well as conflicting information during these past few weeks. I would advise understanding your practice’s payor mix and their policies on telehealth. There are also vast differences in commercial payor guidelines so you must perform your due diligence and research. Medicaid individual state policies also need to be understood before proper coding and billing can occur.
Do you know if CMS will have audits later?
Post-payment audits post-Covid-19 most certainly will occur. Certain elements of telehealth, virtual check-ins, and e-visits may be waived temporarily and CMS has stated they will not be auditing those specific elements, but everything else is up for review. This unprecedented time in our history has opened up telehealth to everyone and auditors still need to be mindful of fraud, waste, and abuse.
What is HIPAA compliant in normal times for telehealth technologies?
Applications for smartphones, iPads, iPads, laptops, desktops that are HIPAA compliant without the imposition of a global-now-national pandemic like COVID-19, include items you may need to purchase like Skype Business. Microsoft does give physicians a Business Associate Agreement (BAA) if they want to use this HIPAA-compliant platform. However, patients must also have an Office365 account linked to the cloud-based Skype Business service.
Can you tell us about any hospital waivers or relaxations for telehealth services in those locations?
Although my webinar focused on Medicare Part B, there are certainly waivers and relaxations that were recently released on March 30, 2020 for Medicare Part A. These allow hospitals and healthcare systems to deliver services at other community-based locations to make room for COVID-19 patients needing acute care in their main facilities. The changes complement and augment the work of the Federal Emergency Management Agency (FEMA) and state and local public health authorities by empowering hospitals and healthcare systems to rapidly expand treatment capacity and separate infected from uninfected patients. CMS’s waivers and flexibilities will permit patients to be triaged to a variety of community-based locales, including ambulatory surgery centers, inpatient rehabilitation hospitals, hotels, and dormitories. Transferring uninfected patients will help hospital staff to focus on the most critical COVID-19 patients, maintain infection control protocols, and conserve personal protective equipment (PPE).
To read the full article, click here.
Nexsen Pruet is one of the largest law firms in the Carolinas, with more than 190 attorneys and offices in Columbia, Charleston, Greenville, Hilton Head and Myrtle Beach, South Carolina, as well as Charlotte, Greensboro and Raleigh, North Carolina. Founded in 1945, Nexsen Pruet provides a broad range of legal services to the business community and represents companies and other entities in local, state, national and international venues.