Telehealth Regulation and Reimbursement

• Indiana
• Michigan
• Illinois
• Kentucky
• Ohio
• Medicare-Medicaid

• Urgent and routine medical care: Providers can use both interactive audio/video and audio-only.
• Outpatient behavioral care: Providers can use both interactive audio/video and audio-only.
• Physical, occupational and speech therapies: Providers must use interactive audio/video technology.
  
  Cost-sharing will be waived for in-network telehealth visits. Out-of-network and cost-sharing will apply, if applicable. Out-of-network telehealth services will be covered in accordance with your health plan benefits.

• What covered entities are included and excluded under the Notification?
• Which parts of the HIPAA Rules are included in the Notification?
• Does the Notification apply to violations of 42 CFR Part 2, the HHS regulation that protects the confidentiality of substance use disorder patient records?
• When does the Notification expire?
• Where can health care providers conduct telehealth?
• What is a “non-public facing” remote communication product?

• We have favorable updates today from Medicare and Medicaid. 
• We should expect private payers to follow.

1. Effective immediately, covered mental health services will be reimbursed as if they took place in person.
2. Telephone and telemedicine visits will be covered for both in- and out-of-state providers and for all covered services. 

• The Indiana Telehealth Announcement
• The Governor's Proclamation from today

• Medicare patients are no longer required to be in an originating site and can now receive telehealth services in their own homes as well as in any health-care facility.
• Telehealth is now available to Medicare beneficiaries in all parts of the country, not just in rural areas.
• Telehealth services are reimbursed for the same dollar amount as in-person visits.
• MS guidance states that HHS will not conduct audits to check whether a psychologists session was a new or a returning patient.
• HHS will exercise enforcement discretion and waive penalties for HIPAA violations against providers who serve patients in good faith through everyday communication technologies, such as FaceTime or Skype, during this public emergency.
• Telephones may be used only with audio and video functions that provide two-way real-time interactive communication. A telephone call without video does not qualify as a telehealth service. (Telephone-only sessions are reasonable and ethically appropriate in many circumstances, but they will not be reimbursed in Medicare at this point. APA will continue to advocate for telephone-only sessions.)

• Psychologists should bill Medicare for telehealth services the same way they bill for an office visit by using the appropriate CPT® code for the service provided. 

• Interactive complexity (90785)
• Psychiatric diagnostic interview (90791)
• Psychotherapy including individual (90832, -34, -37), family (90846, -47), and psychotherapy for crisis (90839, -40)
• Psychoanalysis (90845)
• Health behavior assessment and intervention services, individual and group (96158, -59, -64, -65, -67, -68, -70, 71)
• Neurobehavioral status examination (96116, 96121)

• Psychologists can also bill for brief communications (known as e-Visits) with established Medicare patients. E-Visits involve a brief communication, typically initiated by the patient, and can be furnished in any location or geographic area. Medicare co-insurance and deductible amounts cannot be waived for e-Visits. 
  • To bill for an e-Visit, psychologists would use the following codes:
  • G2061: Qualified healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the seven days: 5-10 minutes.
  • G2062: cumulative time of 11-20 minutes during the seven days
  • G2063: cumulative time of 21 or more minutes during the seven days.
  • More information on e-Visits can be found here.

• • Google G Suite Hangouts Meet
  • Doxy.me
  • Zoom for Healthcare
  • VSee
  • Updox
  • Skype for Business