COVID-19 #VirtualCheckIn #Telehealth

#TeleHealth and #VirtualCheckIn Options for Medical Practices

We are encouraging all of our patients to stay home if at all possible. Especially the elderly and those at increased risk for severe complications from coronavirus infection. However there are still instances were patients need to be evaluated and/or treated. This is where telehealth may be helpful. Another option that I was not aware until yesterday is that of the "virtual check-in". Restrictions on how these evaluation and management options have been loosened somewhat, in hopes that more people will stay at home, and help to "flatten the curve" .

We have been trying to assimilate all available guidance regarding how we can continue to serve our patients while minimizing health risks to our patients, our staff, and ourselves.

This is what I have available regarding 2 potential options for communicating with patients remotely. The 2 options are: 

1. Virtual check-in

2. Telehealth

Virtual check-in checklist:

1. The patient has an established relationship with a physician/physician assistant/nurse practitioner at the practice.

2. The communication is not related to a medical visit within the previous 7 days.

3. The communication does not lead to a medical visits within the next 24 hours after the virtual check-in

4. The virtual check-in is furnished through telephone (HCPCS code G2012)

5. Patient has provided verbal consent for virtual check-in.

6. 5–10 minutes of medical discussion was provided via telephone.

Telehealth:

This is what I could find out about NC BCBS (may not be applicable to other areas):

Blue Cross NC previously required video for virtual care visits. Covering audio-only visits will allow more people to access care at home. This change in coverage is intended to help slow the spread of COVID-19 by limiting exposure, mitigating the surge of demand on our healthcare system and helping protect health professionals on the front lines.

If we are using telephone only for an established Blue Cross Blue Shield patient, (since we cannot establish security of our video or patient’s video) we should use:

1. Codes 99211–99215

2. Place of service (02)

3. CR modifier (stands for catastrophe/disaster–related), since we are using audio only.

4. Coding level should be based upon time.

a. 99211 = 5 minutes

b. 99212 = 10 minutes

c. 99213 = 15 minutes

d. 99214 = 25 minutes

e. 99215 = 40 minutes

Regarding other government payers, this is from HHS.gov as of this morning, March 18, 2020:

“A covered health care provider that wants to use audio or video communication technology to provide telehealth to patients during the COVID-19 nationwide public health emergency can use any non-public facing remote communication product that is available to communicate with patients. OCR is exercising its enforcement discretion to not impose penalties for noncompliance with the HIPAA Rules in connection with the good faith provision of telehealth using such non-public facing audio or video communication products during the COVID-19 nationwide public health emergency. This exercise of discretion applies to telehealth provided for any reason, regardless of whether the telehealth service is related to the diagnosis and treatment of health conditions related to COVID-19.”

Regarding HIPAAA:

The Office for Civil Rights (OCR) at the Department of Health and Human Services (HHS) is responsible for enforcing certain regulations issued under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), as amended by the Health Information Technology for Economic and Clinical Health (HITECH) Act, to protect the privacy and security of protected health information, namely the HIPAA Privacy, Security and Breach Notification Rules (the HIPAA Rules). 

During the COVID-19 national emergency, which also constitutes a nationwide public health emergency, covered health care providers subject to the HIPAA Rules may seek to communicate with patients, and provide telehealth services, through remote communications technologies. Some of these technologies, and the manner in which they are used by HIPAA covered health care providers, may not fully comply with the requirements of the HIPAA Rules. 

OCR will exercise its enforcement discretion and 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. This notification is effective immediately. 

https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html