By: Jacqueline Bain
Here in Florida, where large portions of the population are as transient as migrating birds, doctors and other practitioners often experience a downturn in their practice during the spring and summer months. However, telehealth provides these doctors and practitioners an option to continue treating their patients from afar, provided certain legal and technical requirements are met. The Federal Government and Medicare have been at the forefront of outlining how these services of the future may be properly rendered, allowing for continuity of care in a controlled setting. Medicare, for instance, pays for a limited number of Part B services furnished by a doctor or practitioner to an eligible Medicare beneficiary. To understand how to provide these services, doctors and practitioners must first learn the language.
An “originating site” is where the eligible Medicare beneficiary is located at the time the telehealth service is furnished. Originating sites may be physician offices, hospitals, rural health clinics, Federally Qualified Health Centers, Critical Access Hospitals, Skilled Nursing Facilities, and Community Mental health Centers. Medicare Administrative Contractors pay originating sites an originating site facility fee for telehealth services through HCPCS code Q3014.
A “distant site” is where the doctor or practitioner sits when s/he renders the telehealth services. Practitioners authorized to practice telehealth include physicians, nurse practitioners, physician assistants, nurse midwives, clinical nurse specialists, certified registered nurse anesthetists, clinical psychologists, clinical social workers, registered dieticians or nutritionists, provided such doctors and practitioners are rendering care within the scope of their license.
Telehealth doctors and other telehealth practitioners located at distant sites should submit claims for telehealth payment to their normal Medicare Administrative Contractor using the CPT or HCPCS codes permitted to be rendered via telehealth along with the modifier “GT”. The GT modifier certifies that the Medicare beneficiary was present at an originating site when the telehealth services were rendered. The bill should also use “Place of Service 02: Telehealth.”
From a technical perspective, Medicare requires telehealth doctors and other telehealth practitioners to use interactive audio and video telecommunications systems that permit real-time communication between the doctor or other practitioner at the distant site, and the Medicare beneficiary at the originating site.
State Focus – Florida
In 2016, Florida followed suit, enacting a law that reimburses physicians and other practitioners for fee-for-service telehealth services rendered to Medicaid beneficiaries. The law also created a Telehealth Advisory Council which, among other tasks, compares which health care insurers, HMOs and managed care organizations cover telehealth, whether that coverage is restricted or limited, and how that telehealth coverage compares to that insurer’s coverage for services provided in person. The Council will shape how telehealth is governed by State law in the future, and the Council is required to submit a report to the Governor and State Legislature by December 1, 2018.
Meantime, many commercial insurance providers are exploring their own pathways into providing telehealth services. Florida Blue began offering telehealth services to its members on a limited basis in 2015 and has since expanded its coverage. Aetna uses Teladoc™ to treat and diagnose common illnesses among its Florida Members. And on its website, Humana encourages the use of telemedicine doctors to treat non-emergent illnesses as a supplement to its members’ primary care providers. Reach out to your broker to determine how best to stay within the confines of each commercial insurer, and then be sure to reach out again periodically to stay up to date and ensure telehealth payment.
Once you’ve incorporated telehealth into your practice proper usage may ensure continuity of care for your patients and less of an economic hassle for you in the summer months. Just remember that regulations are evolving rapidly, telehealth payment is evolving and many aspects will vary from state to state.