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Telemedicine and Virtual Services Resources

In the setting of the COVID-19 pandemic, Comagine Health is keenly focused on creating easy access to information and resources to promote and support the rapid adoption of telemedicine. Those at the front lines of health care service delivery don’t have time to sort through all of the latest information and need just-right and just-in-time information to strategize on how best to implement enhanced telemedicine services to:

  • Keep everyone safe
  • Expand access
  • Optimize revenue
  • Adopt a person-centered approach for everyone
  • Plan for virtual health care service delivery post-COVID-19

Our goal is to make the complex simple and to curate resources that make it as easy as possible to find the information you want and need.

What Questions Do You Have?

Have questions about telemedicine? Know of resources or information we should share here? Get in touch through our TeleHelpDesk.

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Centers for Medicare and Medicaid Services

Trump Administration Issues Second Round of Sweeping Changes to Support U.S. Healthcare System During COVID-19 Pandemic

CMS | April 30, 2020 | External Website

Press release with additional provisions to expand telehealth. Note that the following only apply during the public health emergency.

  • Waives limitations on the types of clinical practitioners that can furnish Medicare telehealth services. Previously, only doctors, nurse practitioners, physician assistants and certain others could deliver telehealth services. Now, other practitioners may do so, including physical therapists, occupational therapists and speech language pathologists.
  • Hospitals may bill for services furnished remotely by hospital-based practitioners to Medicare patients registered as hospital outpatients, including when the patient is at home and the home is serving as a temporary provider-based department of the hospital, e.g., counseling, educational services and therapy services.
  • Hospitals may bill as the originating site for telehealth services furnished by hospital-based practitioners to Medicare patients registered as hospital outpatients, including when the patient is located at home.
  • CMS previously announced that Medicare will pay for certain services conducted by audio-only telephone between beneficiaries and their doctors and other clinicians. This adds many behavioral health and patient education services. This also increases payments for these telephone visits to match payments for similar office and outpatient visits — from about $14-$41 to about $46-$110 — retroactive to March 1, 2020.
  • CMS will add new telehealth services on a sub-regulatory basis and is considering requests by practitioners now learning to use telehealth as broadly as possible.
  • Waives the video requirement for certain telephone evaluation and management services and adds them to the list of Medicare telehealth services, allowing Medicare beneficiaries to use an audio-only telephone to get these services.

 

COVID-19 FAQs on Medicare Fee-for-Service Billing

CMS | June 2, 2020 | PDF 

 

 

H.R. 6654 - Emergency COVID Telehealth Response Act 

Congress | May 1, 2020 | External Website

This bill requires CMS to allow, when exercising its waiver authority, the following providers to furnish telehealth services under Medicare during the public health emergency relating to COVID-19 (i.e., coronavirus disease 2019): physical therapists, physical therapist assistants, occupational therapists, occupational therapy assistants, speech-language pathologists, clinical social workers, and audiologists. (Currently, the CMS is authorized to waive requirements for Medicare telehealth services during the public health emergency, and it has done so to allow all providers that are otherwise eligible to furnish in-person services under Medicare to also furnish telehealth services.)

 

 


Medicare Telemedicine Health Care Provider Fact Sheet

CMS | March 17, 2020 | External Website

Includes details on the CMS waiver, types of virtual services, CPT codes, key takeaways and a table summarizing Medicare telemedicine services. Note the section under HIPAA: Penalties for HIPAA violations are waived for clinicians serving patients in good faith using everyday communication, e.g., FaceTime or Skype, during the COVID-19 emergency.


General Provider Telehealth and Telemedicine Tool Kit

CMS | PDF

Summary of the recent telehealth-related regulation changes along with a table with additional resources. CMS subsequently published the ESRD Provider Telehealth and Telemedicine Tool Kit, which is identical to the General Provider Telehealth and Telemedicine Tool Kit with exception of citing two articles that are found on page six in resources listed for the Focus Area “Articles.” CMS also published the Long-Term Care Nursing Homes Telehealth and Telemedicine Tool Kit, which is also identical to the General Provider Telehealth and Telemedicine Tool Kit with the exception of a few resources with an asterisk that are not related to telehealth/medicine.


Medicare Telehealth Frequently Asked Questions (FAQs)

CMS | March 17, 2020 | PDF

Use the link rather than saving the PDF as CMS may update the document.


Medicare Coverage and Payment of Virtual Services

CMS | May 8, 2020 | Video

Clear, simple and well-articulated description of the CMS virtual services.


For any of the categories below, each patient's verbal consent to receive remote services and understanding of any cost sharing must be documented in the patient's medical record. For G2010 and G2012, 99446-99449, 99451 and 99452, CMS permits a single consent (can be verbal or electronic; must be noted in the patient’s chart) to be obtained annually. (Final rule published in the Federal Register Vol. 84, No. 221. Nov. 15, 2019, p. 62699.)


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Medicare Telehealth Services

Telehealth Services

CMS Medicare Learning Network | March 2020 | PDF

Booklet outlining the requirements for providing and billing Medicare telehealth services. While many restrictions have been lifted, this is the best resource for learning about the Medicare telehealth services. For example, the list of distant site practitioners who can furnish and get payment for covered telehealth services on page six has not changed. As of April 6, 2020, CMS has not updated the table of services and codes to include the 2020 codes or the codes added during the public health emergency. Note (also reference below) that during the public health emergency, distant site providers should use the Place of Service (POS) that is the same as what it would have been had the service been furnished in person, using modifier 95, which indicates the service rendered was performed via telehealth.


Medicare Fee-for-Service (FFS) Response to the Public Health Emergency on the Coronavirus (COVID-19)

CMS Medicare Learning Network | April 10, 2020 | PDF

Pay close attention to the information in red text under "Billing for Professional Telehealth Distant Site Services During the Public Health Emergency."


COVID-19 Emergency Declaration: Blanket Waivers for Health Care Providers

CMS | May 15, 2020 | PDF

Retroactive to March 1, 2020.

  • Makes it easier for telemedicine services to be furnished to the hospital's/CAH’s patients through an agreement with an off-site hospital.
  • Allows visits for nursing home residents to be conducted, as appropriate, via telehealth options.
  • Waives requirements that out-of-state practitioners be licensed in the state where they are providing services when they are licensed in another state. Must meet four conditions: 1) enrolled as such in the Medicare program; 2) possess a valid license to practice in the state which relates to his or her Medicare enrollment; 3) furnishing services — whether in person or via telehealth — in a state in which the emergency is occurring in order to contribute to relief efforts in his or her professional capacity; and, 4) not affirmatively excluded from practice in the state or any other state that is part of the 1135 emergency area.
  • Allows clinicians to render telehealth services from their home without reporting home address on their Medicare enrollment while continuing to bill from their currently enrolled location.
  • Allows Medicare beneficiaries in all areas of the country to receive telehealth services, including in their homes.

Telehealth can be delivered to new patients, too. The Department of Health and Human Services (HHS) has announced it will not conduct audits to ensure that telehealth was only provided to established and not new patients during the public health emergency, which has been a requirement for delivering Medicare telehealth services.

On March 30, 2020, CMS released more than 80 new codes for Medicare telehealth services. The full press release is here: Sweeping Regulatory Changes to Help U.S. Healthcare System Address COVID-19 Patient Surge. A summary of the newly added codes is here: Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19. With the codes added as a result of the COVID-19 pandemic, there are 191 Medicare telehealth service codes (as of March 30, 2020). Download a spreadsheet with all codes.


Billing for Professional Telehealth Distant Site Services During the Public Health Emergency

CMS Medicare Learning Network | April 3, 2020 | External Website

When billing professional claims for all telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency, bill with:

  • Place of Service (POS) equal to what it would have been had the service been furnished in-person
  • Modifier 95, indicating that the service rendered was actually performed via telehealth

CMS is not requiring the CR modifier on telehealth services. However, consistent with current rules for telehealth services, there are two scenarios where modifiers are required on Medicare telehealth professional claims:

  • Furnished as part of a federal telemedicine demonstration project in Alaska and Hawaii using asynchronous (store and forward) technology, use GQ modifier
  • Furnished for diagnosis and treatment of an acute stroke, use G0 modifier

There are no billing changes for institutional claims; critical access hospital method II claims should continue to bill with modifier GT.


Informed Consent

Medicare requires beneficiary consent — verbal or written — for telehealth and other virtual services as well as notification of any applicable cost sharing, including potential deductible and coinsurance amounts. Consent must be documented in the patient’s medical record.

  • A single consent may be obtained for multiple communication technology-based services. Single consent must be obtained at least annually (G2010, G2012, 99446-99449, 99551, 99451 and others). (CY 2020 Physician Fee Schedule Final Rule)
  • During the public health emergency (PHE), consent can be documented by auxiliary staff under general supervision or “acquired by staff under the general supervision of the RHC or FQHC practitioner for the virtual communication and monthly care management codes.” (Interim Final Rule April 6, 2020)
  • During the PHE, consent to receive monthly care management, virtual communication services and RPM can be obtained when the services are furnished rather than prior to the service being furnished if obtaining consent would interfere with timely provision of services. Consent must be obtained before the services are billed. (Interim Final Rule April 6, 2020)


Current State Laws & Reimbursement Policies

Center for Connected Health Policy | External Website

Informed consent for telehealth services is required in most states. Find the requirements for your state here.


Telemedicine & Informed Patient Consent: Done the Right Way

eVisit | External Website

Blog post about the basics of informed consent for telehealth and other virtual services. Includes two samples of informed consent.


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Virtual Check-Ins — Virtual Communication Services (VCS)

Brief communication technology-based service, e.g., virtual check-in, by a physician or other qualified health care professional who can report E/M services, provided to an established patient, not originating from a related E/M service provided within the previous seven days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.

  • Via phone call, audio/video communication, secure text messaging, email, or patient portal communication. Source: Final rule published in the Federal Register Vol. 83, No. 226. Nov. 23, 2018, p. 59489.
  • No frequency limitations on the number of times VCS can be billed for a single beneficiary.
  • G20101: Remote evaluation of recorded video and/or images. (Non-facility price: $12.) National payment amount for the non-facility price from the Physician Fee Schedule Search as of April 6, 2020, rounded to the nearest dollar. Do not rely on this. Have your biller/coder double-check.
  • G20121: Brief communication technology-based service, e.g., virtual check-in. (Non-facility price: $15.) National payment amount for the non-facility price from the Physician Fee Schedule Search as of April 6, 2020, rounded to the nearest dollar. Do not rely on this. Have your biller/coder double-check.
  • FQHC/RHC — G0071: Two-in-one code for remote eval or virtual check-in. Reimbursement is set at “the average of the PFS national non-facility payment rates for HCPCS codes G2012 and G2010.” Source: Final rule published in the Federal Register Vol. 83, No. 226. Nov. 23, 2018.
    • To receive payment for the new digital assessment service or virtual communication services (HCPCS codes G2012 and G2010), FQHCs must submit an FQHC claim with HCPCS code G0071 (Virtual Communication Services) either alone or with other payable services. For claims submitted with HCPCS code G0071 on or after March 1, 2020, and for the duration of the COVID-19 PHE, payment for HCPCS code G0071 is set at the average of the national non-facility PFS payment rates for these 5 codes.  Claims for G0071 will be paid at the CY 2020 rate of $13.53 and later reprocessed with the new rate of $24.76.


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E-Visits — Online Digital Evaluation Services

  • Patient-initiated digital communications
  • Requires an interpretation/clinical decision that otherwise typically would have been provided in the office
  • If E/M service in past seven days, cannot use e-visit for that problem
  • Short-term (“up to seven days”) evaluations and assessments
  • Conducted online or via some other digital platform; HIPAA-compliant
  • If more than seven days, may constitute remote patient monitoring
Service Code
Online digital evaluation and management service, for an established patient, for up to seven days, cumulative time during the seven days
  • 99421 — $16
    5-10 minutes
  • 99422 — $31
    11-20 minutes
  • 99423 — $50
    ≥ 21 minutes
Qualified nonphysician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the seven days; 5-10 minutes). Starting Jan. 1, 2020. In the final rule, CMS lists these three codes under the E-Visit section but clarifies that these are to perform an “assessment” rather than an “evaluation.” CMS adds “That the work associated when these services are furnished by a nonphysician practitioner (NPP) will typically be less than when furnished by a physician, due to the acuity of the patient.” Final rule published in the Federal Register Vol. 83, No. 226. Nov. 15, 2019, p. 62795-6.
  • G2061 — $12
    5-10 minutes
  • G2062 — $22
    11-20 minutes
  • G2063 — $34
    ≥ 21 minutes

National payment amount for the non-facility price from the Physician Fee Schedule Search as of April 6, 2020, rounded to the nearest dollar. Do not rely on these. Have your biller/coder double-check.


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Telephone Services

Chronic Care Management (Non-Complex, Complex and Principal Care Management)

These monthly services for providing at least 20 minutes of care coordination and chronic disease management are for Medicare beneficiaries with two or more chronic conditions expected to last for 12 months or until the death of the patient.


Chronic Care Management Services

CMS Medicare Learning Network | July 2019 | PDF

Includes the details about non-complex and complex care management. CMS provides additional information on the Connected Care: The Chronic Care Management Resource website.


Principal Care Management Services is new for 2020 and has not yet been added to CMS resources. This code is very similar to the chronic care management codes but is focused on providing monthly services to an individual with a single high-risk disease. At least for 2020, FQHCs and RHCs cannot bill for PCM. In the CY 2020 Physician Fee Schedule Final Rule, CMS notes they will consider adding PCM to G0511 (the FQHC/RHC general care management code) in future rulemaking.

Service Code
Comprehensive care management services for a single high-risk disease, e.g., Principal Care Management, at least 30 minutes of physician or other qualified health care professional time per calendar month with the following elements: One complex chronic condition lasting at least three months, which is the focus of the care plan, the condition is of sufficient severity to place patient at risk of hospitalization or have been the cause of a recent hospitalization, the condition requires development or revision of disease specific care plan, frequent adjustments in the medication regimen, and/or the management of the condition is unusually complex due to comorbidities.

G2064 — $92

Same as above. Just insert “clinical staff time directed by a physician or other qualified health care professional” in place of "physician or other qualified health care professional."

G2065 — $40

National payment amount for the non-facility price from the Physician Fee Schedule Search as of April 6, 2020, rounded to the nearest dollar. Do not rely on these. Have your biller/coder double-check.


Telephone Calls Without Video

Service Code
Comprehensive care management services for a single high-risk disease, e.g., Principal Care Management, at least 30 minutes of physician or other qualified health care professional time per calendar month with the following elements: One complex chronic condition lasting at least 3 months, which is the focus of the care plan, the condition is of sufficient severity to place patient at risk of hospitalization or have been the cause of a recent hospitalization, the condition requires development or revision of disease specific care plan, frequent adjustments in the medication regimen, and/or the management of the condition is unusually complex due to comorbidities.

G2064 — $92

Same as above. Just insert “clinical staff time directed by a physician or other qualified health care professional” in place of "physician or other qualified health care professional."

G2065 — $40

National payment amount for the non-facility price from the Physician Fee Schedule Search as of April 6, 2020, rounded to the nearest dollar. Do not rely on these. Have your biller/coder double-check.


Telephone Evaluation and Management (E/M) Services

  • Only for the duration of the public health emergency
  • New or established patients
  • May be furnished by, among others, LCSWs, clinical psychologists, and physical therapists, occupational therapists and speech language pathologists when the visit pertains to a service that falls within the benefit category of those practitioners
Service Code
Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent or guardian not originating from a related E/M service provided within the previous seven days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment.
  • 99441 — $46
    5-10 minutes
  • 99442 — $76
    11-20 minutes
  • 99443 — $110
    21-30 minutes
Telephone assessment and management service provided by a qualified nonphysician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous seven days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment.
  • 98966 — $14
    5-10 minutes
  • 98967 — $28
    11-20 minutes
  • 98968 — $41
    21-30 minutes


Interprofessional Consultation Services

Service Code
Interprofessional telephone/internet/electronic health record assessment and management service provided by a consultative physician, including a verbal and written report to the patient’s treating/requesting physician or other qualified health care professional)

99446 — $18

99447 — $37

99448 — $56

99449 — $74

Interprofessional telephone/internet/electronic health record assessment and management service provided by a consultative physician, including a written report to the patient’s treating/requesting physician or other qualified health care professional), five minutes or more of medical consultative time

99451 — $38

Interprofessional telephone/internet/electronic health record referral service(s) provided by a treating/requesting physician or other qualified health care professional, 30 minutes

99452 — $38

National payment amount for the non-facility price from the Physician Fee Schedule Search as of April 6, 2020, rounded to the nearest dollar. Do not rely on these. Have your biller/coder double-check.


Behavioral Health Integration (BHI) Services

Note: The BHI Codes allow for remote provision of certain services by the psychiatric consultant and other members of the care team.


Behavioral Health Integration Services

CMS Medicare Learning Network | May 2019 | PDF


Frequently Asked Questions about Billing Medicare for Behavioral Health Integration (BHI) Services

CMS | April 17, 2018 | PDF


Remote Physiologic Monitoring (RPM)

Remote Physiologic Monitoring Fact Sheet

Comagine Health | May 2020 | PDF

Highlights:

  • Beneficiary’s consent — verbal or written — to receive RPM and notification of any applicable cost sharing must be documented in the patient’s medical record.
  • During the public health emergency (PHE), RPM services can be:
    • Used for physiologic monitoring for chronic and/or acute conditions, e.g., in the case of an acute respiratory virus, pulse and oxygen saturation levels using pulse oximetry
    • Furnished to new patients as well as established patients starting March 1, 2020, and for the duration of the PHE
    • Initiated for patients for whom a face-to-face visit has not occurred
    • Delivered without the requirement of cost-sharing by the patient
    • Reported for shorter periods of time than 16 days if the other code requirements are met
  • Nurses, working with clinicians, can check with the patient and then, using patient data, determine whether home treatment is safe.
  • RPM and chronic care management codes, including Principal Care Management (new for 2020) can be billed concurrently by the same practitioner for the same beneficiary, provided the time is not counted twice.

 

Service Code
Remote monitoring of physiologic parameter(s), e.g., weight, blood pressure, pulse oximetry, respiratory flow rate, initial; set up and patient education on use of equipment

99453 — $19

Remote monitoring of physiologic parameter(s), e.g., weight, blood pressure, pulse oximetry, respiratory flow rate, initial; device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days

99454 — $62

Base code: Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; initial 20 minutes

99457 — $52

Add-on code: Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; additional 20 minutes

99458 — $42

Collection and interpretation of physiologic data, e.g., ECG, blood pressure, glucose monitoring, digitally stored and/or transmitted by the patient and/or caregiver to the physician or other qualified healthcare professional, qualified by education, training, licensure/regulation (when applicable) requiring a minimum of 30 minutes of time, each 30 days

99091 — $59

Self-measured blood pressure using a device validated for clinical accuracy; patient education/training and device calibration

99473 — $11

Separate self-measurements of two readings one minute apart, twice daily over a 30-day period (minimum of 12 readings), collection of data reported by the patient and/or caregiver to the physician or other qualified health care professional, with report of average systolic and diastolic pressures and subsequent communication of a treatment plan to the patient

99474 — $15

National payment amount for the non-facility price from the Physician Fee Schedule Search as of April 6, 2020, rounded to the nearest dollar. Do not rely on these. Have your biller/coder double-check.


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Setting- or Condition-Specific Information

Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs)

New and Expanded Flexibilities for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) During the COVID-19 Public Health Emergency (PHE)

CMS Medicare Learning Network | April 30, 2020 | PDF

Important information for all FQHCs and RHCs. Includes details on coding and reimbursement depending on date services provided — Jan. 27, 2020, through June 30, 2020, or July 1, 2020, to the end of the PHE. Also covers:

  • New payment for telehealth services, including how to bill Medicare
  • Expansion of virtual communication services
  • Revision of home health agency shortage requirement for visiting nursing services
  • Consent for care management and virtual communication services
  • Accelerated/advance payments


Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs): CMS Flexibilities to Fight COVID-19

CMS | April 29, 2020 | PDF

Additional helpful detail for RHCs and FQHCs, especially around telehealth and virtual services.


Federally Qualified Health Centers & Rural Health Clinics Acting as Distant Site Providers in Medicare

Center for Connected Health Policy | April 30, 2020 | PDF

Summary of CMS guidance on new and expanded flexibilities given to FQHCs and RHCs during the COVID-19 public health emergency.


Long-Term and Post-Acute Care (LTPAC)

Telehealth in Long-Term and Post-Acute Care Facilities

Comagine Health | April 2020 | PDF

Internal messaging for facilities about teleservice categories, codes and reimbursement, as well as important actions to ensure timely, quality care and prevent the spread of COVID-19.


A Practical Guide to Telehealth: Implementing Telehealth in Post-Acute and Long-Term Care Settings

West Health | PDF

 

Behavioral Health

Resources and Tools for Addressing COVID-19 

National Council for Behavioral Health | External website 

A general hub for all COVID-19 resources, including specific telehealth resources and behavioral health information applicable to any setting. 

 

Best Practices for Telehealth During COVID-19

National Council for Behavioral Health | PDF 

 

Telepsychiatry and COVID-19 

American Psychiatric Association | External Website 

 

Telehealth Toolkit 

American Psychiatric Association | External Website 

A toolkit for implementing telepsychiatry that provides resources for legal and reimbursement issues, clinical implementation, and technological considerations.

 

Telehealth for Social Workers 

National Association of Socials Workers | External Website  

Resource for licensed clinical social workers containing current requirements for providing telehealth services and related materials. 

 

Telehealth and Clinical Training Resources During COVID-19 

Unversity of Washington AIMS Center | External Website

Includes a list of resources from clinical, policy and financial perspectives on administering telehealth, with particular attention to COVID-19. 

 

COVID-19 Supporting Access to Telehealth

American Society of Addiction Medicine | External Website


Substance Use Disorder/Opioid Use Disorder

FAQs: Provision of Methadone and Buprenorphine for the Treatment of Opioid Use Disorder in the COVID-19 Emergency

Substance Abuse and Mental Health Services Administration (SAMHSA) | April 21, 2020 | PDF


Treating Opioid Use Disorder Via Telehealth Tips for Primary Care Providers

Providers Clinical Support System | Word

Frequently asked questions for those treating individuals with substance/opioid use disorder.


Use of Telephone Evaluations to Initiate Buprenorphine Prescribing

DEA | March 31, 2020 | PDF

“In light of the extraordinary circumstances presented by the COVID-19 public health emergency, and being mindful of the exemption issued by SAMHSA, DEA likewise advises that, only for the duration of the public health emergency (unless DEA specifies an earlier date), OTPs should feel free to dispense, and DATA-waived practitioners should feel free to prescribe, buprenorphine to new patients with OUD for maintenance treatment or detoxification treatment following an evaluation via telephone voice calls, without first performing an in-person or telemedicine evaluation.”


Informational Bulletin: Medicaid Substance Use Disorder Treatment Via Telehealth

CMS | April 2, 2020 | PDF

Although this is a comprehensive guidance document, it does not have information specific to treating patients during the COVID-19 pandemic.


Medications for Addiction Treatment (MAT) Management During COVID 19: 6 Takeaways

Center for Care Innovations | March 30, 2020 | External Website


Practice Guidance for COVID-19

American Psychiatric Association | External Website


COVID-19 Public Health Emergency Response and 42 CFR Part 2 Guidance

SAMHSA | PDF

Brief guidance to ensure substance use disorder treatment services are uninterrupted during the public health emergency.


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State-Specific Information

COVID-19 Related State Actions

Center for Connected Health Policy | External Website

Table of actions each state has taken to remove policy barriers to telehealth utilization during the pandemic.


Idaho

Per the the Idaho Medical Association (IMA) IMAges newsletter dated May 15, 2020: During a May 7 meeting with the Idaho Department of Insurance (DOI), the DOI indicated the five major Idaho insurance companies — Blue Cross of Idaho, Regence Blue Shield, PacificSource, SelectHealth and Mountain Health CO-OP — had informed the DOI they have been reimbursing at in-person rates for telehealth visits since early April 2020. The IMA advised providers to respond directly to insurance companies to resolve claims not paid at in-person rates. If unable to resolve the issue with the insurance company, IMA staff can provide assistance.


Idaho Department of Health and Welfare Information Releases

All Information Releases

Telemedicine-Related Information Releases


Idaho Telehealth Council

Idaho Department of Health and Welfare | External Website

Resources developed under the State Innovation Model Grant (prior to the coronavirus pandemic).


Telehealth Reimbursement Matrix

Idaho Telehealth Council | March 2018 | PDF

 

New Mexico

Telehealth information from the Medicare Administrative Contractor for New Mexico  

 

Oregon

Telehealth Coverage Finder 

DataDx | External Website 

This online tool allows providers to look up billing codes and coverage for all major payers in Oregon. 

 

Utah

COVID-19 and Telehealth Resources

Utah Telehealth Network | External Website

Utah-specific and general telehealth resources.


COVID-19 Telehealth Resource Center

Utah Department of Health | PDF

 

Quick Start Guide to Telehealth 

Northwest Regional Telehealth Resource Center | PDF

 

 

Washington

The Washington State Health Care Authority has Zoom licenses available for providers who want to offer telemedicine. These licenses are HIPAA and 42 CFR Part 2 compliant.

Request a Zoom license

Read HCA's Zoom Telehealth Frequently Asked Questions

 

Apple Health (Medicaid) Telemedicine & Telehealth Brief

Washington State Health Care Authority | April 23, 2020 | PDF

Includes policies, best practices, billing guidance, resources and more.


Apple Health (Medicaid) Behavioral Health Policy and Billing During the COVID-19 Pandemic

Washington State Health Care Authority | April 8, 2020 | PDF


License Expiration Extension FAQs

Washington State Department of Health | External Website

“There are roughly 215,000 health care providers whose licenses will expire between April 1 and September 30, 2020.” To ameliorate this problem, the Washington Secretary of Health has implemented a temporary extension of health profession licenses. All active license types for all professions expiring between April 1 and Sept. 30 will have license expiration dates extended to Sept. 30, 2020.


Sign Language Interpreter Services Solutions During COVID-19

Washington State Department of Social and Health Services | External Website

Guidance on how to have a sign language interpreter participate remotely in appointments.


Coming Soon

Information and resources for Nevada.


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Regulatory Resources

HIPAA and Security

HIPAA, Civil Rights, and COVID-19

HHS | External Website

New HHS Office for Civil Rights (OCR) webpage with all COVID-19-related materials they have issued. Answers questions about telehealth, COVID-19 and HIPAA.

  • OCR “Will not impose penalties for violations of certain provisions of the HIPAA Privacy Rule against health care providers or their business associates for the good faith uses and disclosures of protected health information (PHI) by business associates for public health and health oversight activities during the COVID-19 nationwide public health emergency.”
  • OCR “Will not impose penalties for noncompliance with the regulatory requirements under the HIPAA Rules against covered health care providers in connection with the good faith provision of telehealth during the COVID-19 nationwide public health emergency.”
  • While not appropriate for a long-term solution, during COVID-19, “Covered health care providers may use popular applications that allow for video chats, including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, Zoom, or Skype, to provide telehealth without risk that OCR might seek to impose a penalty for noncompliance with the HIPAA Rules related to the good faith provision of telehealth during the COVID-19 nationwide public health emergency.”
  • “Facebook Live, Twitch, TikTok, and similar video communication applications are public facing, and should not be used in the provision of telehealth by covered health care providers.”

Source: Notification of Enforcement Discretion under HIPAA to Allow Uses and Disclosures of Protected Health Information by Business Associates for Public Health and Health Oversight Activities in Response to COVID-19, accessed April 2, 2020.


FAQs on Telehealth and HIPAA During the COVID-19 Nationwide Public Health Emergency

HHS Office for Civil Rights | PDF


Notification of Enforcement Discretion for Telehealth Remote Communications During the COVID-19 Nationwide Public Health Emergency

HHS | External Website

Use telehealth technology that is HIPAA-compliant and use only vendors that enter into business associate agreements (BAA) in connection with provision of their telehealth products. OCR lists a few vendors: Skype for Business/Microsoft Teams, Updox, VSee, Zoom for Healthcare, Doxy.me, Google G Suite Hangouts Meet, Cisco Webex Meetings/Webex Teams, Amazon Chime, GoToMeeting and Spruce Health Care Messenger.


FBI Warns of Teleconferencing and Online Classroom Hijacking During COVID-19 Pandemic

FBI | March 30, 2020 | External Website

  • “Do not make meetings or classrooms public. In Zoom, there are two options to make a meeting private: require a meeting password or use the waiting room feature and control the admittance of guests.
  • Do not share a link to a teleconference or classroom on an unrestricted publicly available social media post. Provide the link directly to specific people.
  • Manage screensharing options. In Zoom, change screensharing to ‘Host Only.’
  • Ensure users are using the updated version of remote access/meeting applications. In January 2020, Zoom updated their software. In their security update, the teleconference software provider added passwords by default for meetings and disabled the ability to randomly scan for meetings to join.
  • Lastly, ensure that your organization’s telework policy or guide addresses requirements for physical and information security.”


The Cybersecurity and Infrastructure Security Agency also recommends the following video-teleconferencing (VTC) cybersecurity resources:


HHS Office of the Inspector General (OIG)

Waiving Telehealth Cost-Sharing During Covid-19 Outbreak

Provides flexibility for healthcare providers to reduce or waive beneficiary cost-sharing for telehealth visits paid by federal healthcare programs.


Drug Enforcement Agency (DEA)

COVID-19 Information Page

DEA | External Website

“DEA-registered practitioners in all areas of the United States may issue prescriptions for all schedule II-V controlled substances to patients for whom they have not conducted an in-person medical evaluation, provided all of the following conditions are met:

  • The prescription is issued for a legitimate medical purpose by a practitioner acting in the usual course of his/her professional practice;
  • The telemedicine communication is conducted using an audio-visual, real-time, two-way interactive communication system; and
  • The practitioner is acting in accordance with applicable Federal and State laws.”

Accessed April 2, 2020.


How to Prescribe Controlled Substances to Patients During the COVID-19 Public Health Emergency

DEA | PDF

One-page process map for prescribing controlled substances that includes any provisions/exceptions resulting from the COVID-19 pandemic.


Exception to Separate Registration Requirements Across State Lines

DEA |PDF

“Under the exception being announced today, DEA-registered practitioners are not required to obtain additional registration(s) with DEA in the additional state(s) where the dispensing (including prescribing and administering) occurs, for the duration of the public health emergency declared on January 31, 2020, if authorized to dispense controlled substances by both the state in which a practitioner is registered with DEA and the state in which the dispensing occurs. Practitioners, in other words, must be registered with DEA in at least one state and have permission under state law to practice using controlled substances in the state where the dispensing occurs.”


Health Resources & Services Administration (HRSA)

Coronavirus Disease 2019 (COVID-19) Frequently Asked Questions

There are several telehealth related Q&As embedded in this website, including whether FQHCs can serve as distant site providers.

Question: “Can health centers bill Medicare for telehealth services as distant site providers?”

Answer: “During this emergency period, Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) are now eligible to provide telehealth services to Medicare beneficiaries as distant site providers.

“The Coronavirus Aid, Relief, and Economic Security (CARES) Act revises the definition of a distant site in section 1834(m)(2)(A) of the Social Security Act to include FQHCs or RHCs that furnish a telehealth service to an eligible telehealth individual during the COVID-19 public health emergency period. Rural and site limitations are removed, so that telehealth services furnished during the emergency period can be provided regardless of the geographic location of the Medicare beneficiary, including if the patient is at home. Telehealth services include medical outpatient office visits, behavioral health services, and other visits currently eligible under the Medicare telehealth reimbursement policies. In order to be eligible for reimbursement, providers must use telecommunication systems with both audio and video capabilities for two-way, real-time interactive communication.

“Note that Medicare reimbursement will continue to be provided to FQHCs that use technology-based services furnished through patient-initiated e-visits via an online patient portal or virtual check-ins with a provider.”


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Technology

Telehealth Product Comparison

Mountain-Pacific Quality Health | Excel


Video Conferencing Technology Decision Matrix

Prime Health | Google Doc


AT&T Providing Virtual House Calls

“AT&T has paired up with ‘virtual care’ company VitalTech to offer free access to remote healthcare. The company says it is offering 60 days of free telehealth services via the VitalCare platform to business customers, including hospitals and doctors' offices.”


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Patient Resources

Making the Most of your Virtual Health Care Visit

Comagine Health | PDF

Guidance to help patients prepare for and participate in teleservices. We are grateful for the input and improvements from our Patient and Family Advisory Council.


What to Expect From a Telehealth Visit

Hawaii State Department of Health | Video

Good resource to send to patients in advance of their telehealth visit.


How to Prepare for a Video Appointment With Your Mental Health Clinician

American Psychiatric Association and Substance Abuse and Mental Health Services Administration | PDF

One-pager for patients on what to do before the day of the video appointment, on the day of the appointment and just before the appointment starts.


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Other Recommended Resources

National Consortium of Telehealth Resource Centers

External Website

“Telehealth Resource Centers (TRCs) have been established to provide assistance, education, and information to organizations and individuals who are actively providing or interested in providing health care at a distance. Our simple charter from the Office for Advancement of Telehealth is to assist in expanding the availability of health care to rural and underserved populations. And because we are federally funded, the assistance we provide is generally free of charge.”


Northwest Regional Telehealth Resource Center

External Website

Serving Alaska, Idaho, Montana, Oregon, Utah, Washington and Wyoming.


Southwest Telehealth Resource Center

External Website

Serving Arizona, Colorado, Nevada, New Mexico and Utah.


Quick Start Guide to Telehealth During COVID-19

Northwest Regional Telehealth Resource Center | PDF

Practical guidance for health care providers who want to use simple, web-based video to interact with patients.


Telemedicine Glossary

American Telemedicine Association | External Website

Comprehensive list of telemedicine terms.


Center for Connected Health Policy

External Website

The National Telehealth Policy Resource Center. Use this site to keep track of the telehealth policy changes in the setting of COVID-19. Consider signing up for their updates. Includes a summary of what is covered by various public and private payers in the Telehealth Coverage Policies in the Time of COVID-19 document, and an at-a-glance State Telehealth Laws & Reimbursement practices, as well as a comprehensive overview of the same practices. 


Quick Guide to Telemedicine in Practice

American Medical Association | External Website

"Quick guide to support physicians and practices in expediting the implementation of telemedicine” that is continually updated. Includes the comprehensive Telehealth Implementation Playbook.

 

Coding Advice During COVID-19 

American Medical Association | PDF 

 

A Physician Practice Guide to Reopening 

American Medical Association | PDF


COVID-19 Resources

California Quality Collaborative | External Website

Several teleservice-related resources and webinar opportunities.


Telehealth and Telephone Visits in the Time of COVID-19: FQHC Workflows and Guides

Center for Care Innovations | External Website

Practical workflows and other information.


Maintaining Person-Centered Care: A Guide to Telehealth Etiquette

Comagine Health | PDF

Guide to help clinicians improve how they deliver virtual teleservices.


Telehealth Best Practices

Hawaii State Department of Health | Video

Short video highlighting best practices for delivering telemedicine, including lighting, eye contact and appearance.


Telehealth Guidance for COVID-19 Communications

Patient Priorities Care | PDF

Conversation guide for conducting effective telehealth clinic visits based on the principles of Patient Priorities Care. PPC is a structure for having conversations with older patients about what matters most to them —their health values, outcome goals and health care preferences — and making collaborative health care decisions.


Telehealth Startup Guide

Center to Advance Palliative Care | PDF

Six components for integrating telehealth into a palliative care program.
 

CARES Act

PDF

Signed March 25, 2020. Contains telehealth-related provisions.


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Additional Information

 

The FCC is disbursing $200 million to support health care providers’ use of telehealth. They are also launching Connected Care Pilot Program, a three-year program with $100 million to provide universal service support to help defray health care providers’ qualifying costs of providing connected care services. 

As of May 20, the FCC has approved just over $50 of the $200 million. You can check this list to see the awardees (as of May 20, 2020). 

 

COVID-19 Telehealth Services 

UnitedHealthcare | Website

 

Experian Health Provides Free List of COVID-19 and Telehealth Payer Policy Alerts 

Hospitals and healthcare organizations can register here to access the list*

*Comagine Health is not responsible for the accuracy of the information posted in the Experian links. 

 

 

Advocacy

Many professional organizations are advocating to keep select telehealth regulation changes that have been put in place as a result of the pandemic and the public health emergency. As we are notified, we will track those advocacy efforts here. 

 

American Psychiatric Association (APA) Lobbies to Make Telehealth Waivers Permanent 

The APA (and others) are calling on Congress to lift restrictions on telehealth that were loosened during the public health emergency. The APA is also asking for the elimination of the rule that requires clinicians to have an initial face-to-face meeting with patients before they can prescribe controlled substances. 

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