To encourage patients to seek medical attention from their homes rather than visiting a hospital or doctor's office, the Center for Medicaid & Medicare Services (CMS) will start reimbursing physicians and non-physician practitioners for "virtual check-ins" -- brief, virtual services with your established provider where the communication is not related to a medical visit within the previous 7 days and doesn't lead to a medical visit within the next 24 hours.

Patients can be briefly evaluated over the phone, through recorded video messages or via live video interactions. Practitioners may educate beneficiaries on the availability of telehealth services; however, the services must be requested by the patient before the evaluation. Patient consent must be documented. Practitioners must continue to practice caution and use only secure methods of communication and to ensure patient privacy and maintain HIPPA compliance.

For the evaluations and management (E/M) and other services provided directly in a beneficiary's home, CMS has provided the following billing codes: HCPCS Code G2012 can be used for synchronous technology, such as a telephone call or a virtual check in. HCPCS Code G2010 can be used for asynchronous technology such as a remote evaluation of recorded videos sent through email by a current patient. For use in an online patient portal, use CPT codes 99421-99423 for patient-initiated digital communication, and HCPCS codes G2061-G2063 for online assessments.

Other government agencies are stepping in to encourage telemedicine. The New York State Department of Financial Services (DSF) is going to require insurance companies to waive co-pays for telehealth visits.

To learn more about telehealth issues surrounding the COVID pandemic, call us at 212-668-0200 or by email at info@mdrxlaw.com.