Sonal Patel, Health Care Coder and Compliance Consultant for Nexsen Pruet, recently presented the webinar “Compliant Coding & Billing For TeleHealth During COVID-19” which can now be viewed here. Sonal returned to answer many commonly asked questions in relation to this presentation.

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).

Sonal Patel CPMA, CPC, CMC, ICD-10-CM is a healthcare coding and compliance consultant at the law firm of Nexsen Pruett, LLC. She has over 10 years of experience in multi-specialty healthcare coding and auditing. She provides reimbursement investigations for both Parts A and B providers. Patel provides healthcare lawyers with strategies and analyses to overturn denials with private and government payors. 

Be sure to view a replay of Sonal’s webinar Compliant Coding & Billing For TeleHealth During COVID-19 . Be sure to also check out our other COVID-19 webinars on this blog article as well as our on-demand webinars in our shopping cart as part of our online compliance training courses and get ready for our Virtual Healthcare Compliance Symposium on April 23.  A full-day of learning with available CLEs and CEUs!