Hello everyone, and welcome to our Monday Minute. As was promised, today we’re going to discuss the Public Health Emergency waivers, specifically related to Telehealth and where that has taken us.
With the Telehealth waivers, you are allowed to conduct several things via Telehealth and with the appropriate documentation. One of the biggest battles being that you are not allowed to report those Telehealth visits on your claims. That is true whether you are a Home Health agency or a Hospice. Neither are allowed to report Telehealth visits on the claim. The thing I wanted to really stress today and make sure that you are fully aware of, is that these Telehealth visits must be two things: First of all, they must be reported in your plan of care or orders that specifically state that the visit is going to be conducted via Telehealth. You cannot just wake up one day and say, “I think I’ll just do Telehealth visits today”, instead of the scheduled visits that you had in your care plan. It must be that they were written in the orders as Telehealth visits. In addition to that, those Telehealth visits must be conducted via two-way audio video, if they are specifically face to face encounters. Whether that be a face-to-face encounter that’s being conducted by a community physician, in order to get the Home Health agency a face-to-face encounter they need, or whether it is the staff of a Hospice that is conducting the face-to-face encounter for a Hospice patient. The encounter itself must be both audio and video. And in addition to that, it has to be that the physician has documented, or the practitioner has documented, in their note that it was both audio and video. The patient must be able to see and hear the physician and the physician must be able to see and hear the patient. In addition to that, you have to ensure that these visits are not showing up on your claims. They are not allowed visits that would impact reimbursement. They do not count toward your LUPA threshold in Home Health specifically, and even for Hospice they again are not reported on your claims.
We did have a little bit of good news this past week. I don’t know that I’ve ever said those two words in conjunction with MedPAC before. Just recently MedPAC had a meeting and voted on the information that would be put in their annual report to Congress. MedPAC did vote on and say that being included in their report to Congress in March of 2022, they will include a recommendation that Home Health agencies be required to begin reporting Telehealth visits that are conducted during 30-day payment periods. The good news about that is I think this heads us down the path that we’ve already been trying to establish in getting approval, eventually put into regulation, that Telehealth visits be allowed for payment purposes. As of right now, of course, through the Medicare program, you cannot be reimbursed for those Telehealth visits. There are other payers that you might be able to get paid for Telehealth, but not for Medicare at this time.
I just wanted to make sure that we’re very clear about the fact that you are still allowed to do Telehealth visits. You are required to have those audio and video if they are face-to-face encounters, and it must be documented as such. Why is that such a big deal? It’s such a big deal because there are being denials handed out left and right by medical reviewers, by all medical review contractors, including Pre-Claim Review under the Review Choice Demonstration, if there is not adequate documentation to support that the call for the Telehealth encounter was both audio and video. There is also reality that many of the allowances for Telehealth to replace (in-person visits) will go away when the waivers go away. We’ve always been allowed to do Telehealth visits. You’ll just need to be very, very particular, if and when this Public Health Emergency does end, because the fact that face to face encounters currently include the option of them being done via Telehealth that will go away unless something changes between now and then when the Public Health Emergency expires.
Thank you all for participating and watching today. Again, please stay strong as we continue to move our way through this Public Health Emergency and taking care of patients on the frontlines. We are so appreciative of everything you do for them, on a daily basis, in trying to keep our country as healthy as you possibly can.
Stay tuned again to your state and national Homecare associations. Education is being developed by all of those, many of them will be having live events for their annual conferences this spring, fall and summer and we hope to see you at many of those. Have a fabulous week and we will talk again next Monday.
Don’t miss our next HPS Alliance webinar
QAPI – Hospice Webinar February 24, 2022!