Telehealth Billing for Michigan RHCs and CAHs
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1 Telehealth Billing for Michigan RHCs and CAHs Jonathan Neufeld, PhD Upper Midwest Telehealth Resource Center Michigan Center for Rural Health Webinar June 10, 2015 This project is/was supported by the Health Resources and Services Administration (HRSA) of the U.S. Department of Health and Human Services (HHS) under grant number G22RH under the Telehealth Resource Center Grant Program for $325,000. This information or content and conclusions are those of the author and should not be construed as the official position or policy of, nor should any endorsements be inferred by HRSA, HHS or the U.S. Government.
2 Objectives Participants will understand the resources available to them to help in developing, sustaining, and evaluating their telehealth programs. Participants will understand the regulatory framework within which telehealth service operate. Participants will develop a working knowledge of how to properly bill for telehealth services. 2
3 Outline Intro to UMTRC and National TRC Program Telehealth as a Component of Your Clinical Business Billing for Services Provided via Telehealth Questions 3
4
5 telehealthresourcecenters.org Links to all TRCs National Webinar Series Reimbursement, Marketing, and Training Tools
6 UMTRC Services Presentations & Trainings Individual and Group Consultation Training and Technical Assistance Connections with other programs Program Design and Evaluation Information on current legislative and policy developments
7 Outline Intro to UMTRC and National TRC Program Telehealth as a Component of Your Clinical Business Billing for Services Provided via Telehealth Questions 7
8 Basic Reimbursement Model Rural originating site Specialist at distant site Facility Fee (Part B) Professional Fee (Part B)
9 Three Domains of Telehealth Hospital & Specialties Specialists see and manage patients remotely Integrated Care Mental health and other specialists work in primary care settings (e.g., PCMH s, ACO s) Transitions & Monitoring Patients access care (or care accesses patients) where and when needed to avoid complications and higher levels of care **Value proposition differs among these types** 9
10 Hospital and Specialty Care 10
11 Three Domains of Telehealth Hospital & Specialties Specialists see and manage patients remotely Integrated Primary Care Mental health and other specialists work in primary care settings (e.g., PCMHs, ACOs) Transitions & Monitoring Patients access care (or care accesses patients) where and when needed to avoid complications and higher levels of care **Value proposition differs among these types** 11
12 Integrated Primary Care 12
13 Three Domains of Telehealth Hospital & Specialties Specialists see and manage patients remotely Integrated Care Mental health and other specialists work in primary care settings (e.g., PCMH s, ACO s) Transitions & Monitoring Patients access care (or care accesses patients) where and when needed to avoid complications and higher levels of care **Value proposition differs among these types** 13
14 Transitions and Monitoring 14
15 Hub and Spoke Telemedicine pt ptptpt pt ptptpt Spoke pt Spoke pt pt ptptpt Spoke pt pt ptptpt Spoke pt pt ptptpt Spoke pt MD MD NP MD HUB DO MD MD PhD pt ptptpt Spoke pt
16 Peer to Peer Telemedicine MD MD tele commuters NP MD CSW PhD pt pt pt pt pt pt pt pt pt pt pt pt pt pt pt pt CHC pt pt pt pt pt pt pt pt pt pt pt pt pt pt pt NP DO
17 Peer to Peer Telemedicine Peer to Peer Model Clinicians anywhere Patients anywhere Patient site bills, receives payment Clinician gets paid by patient site (as an employee or contractor) Clinicians anywhere Patients anywhere Patient site bills, receives payment Clinician gets paid by patient site (as an employee/contractor) Telecommuting (Indiana & Illinois)
18 P2P Putting the Clinic in Charge Rather than connecting with a large health system, RHCs/CAHs can hire/contract directly with the clinicians/services they need RHC/CAH drives the project RHC/CAH chooses clinicians/services/format RHC/CAH bills for services RHC/CAH pays clinician RHC/CAH maintains ownership/control 18
19 Telehealth Services are Your Services 19
20 Outline Intro to UMTRC and National TRC Program Telehealth as a Component of Your Clinical Business Billing for Services Provided via Telehealth Questions 20
21 Business Models New Revenue New staff, new service Reduced Expense Less travel for clinicians Increased Efficiency More encounters, fewer no shows Greater Value More/better services available on site 21
22 Equipment Standard Video End Point ($5,000) Mini codec (LifeSize Passport) 37 TV (monitor + speakers) Desktop stand or rolling cart Web based System ($1,500) Mini computer + HD webcam TV monitor + speakers Software (Zoom, Vidyo, etc.) Desktop stand or rolling cart
23 Equipment Web based System ($500) All in one desktop computer HD webcam Software package
24 INVESTMENT (Costs) Equipment (minimum, half of average) Video only $1,000 + $100/yr per site Video plus peripherals $5,000 + $1,000p + $500/yr per site Internet Connectivity Cable 3 Mbps (symmetric/business) Time (decision making; training) 24
25 Michigan Licensure Law Licensure Requirements: full medical license required to do telemedicine in MI. Reciprocity: The Board does allow application based on 10+ years of licensure in another state (2 years with verification of training). Internet Prescribing prescribing medications based solely on[ ]an online questionnaire[ ] constitutes substandard medical care[ ]. (FSMB Position Statement, 2002)
26 Michigan Law Michigan is the only state that requires an outof state physician to hold a full Michigan medical license even if the physician is merely providing remote, consultative services.
27 Reimbursement Overview Medicare Limited CPTs Rural areas only Medicaid Yes; same as in person Limited set of providers/formats Private Payers Mandated reimbursement
28 Medicare Reimbursement Published Annually 6 pages All allowable codes, providers, and locations
29 29
30 Many services can be billed multiple ways Most basic are usually allowed Many screening and prevention services allowed 30
31 Update to HPSA Rural Designation Effective January 1, 2014: Otherwise eligible sites in health professional shortage areas (HPSAs) located in rural census tracts of MSA counties are eligible originating sites. (RUCA codes 4 10 and 2 3 in counties over 400 sq. mi., Pop <35/sq. mi.) Eligibility Lookup Tool visor/telehealtheligibility.aspx
32 Coverage for Transitional Services Effective January 1, 2014: CPT codes and added Communication (direct, telephone, or electronic) with the patient and/or caregiver within 2 business days of inpatient discharge Medical decision making of at least moderate (or high) complexity during the service Follow up face to face (in person) visit within 14 (or 7) calendar days of discharge
33 CMS 2015 New Telehealth Codes Mental Health (psychoanalysis) (family psychotherapy without the patient present) (conjoint family psychotherapy with patient present) (prolonged service in the office or other outpatient setting; first hour) (list separately in addition to office or other outpatient E&M Code) (prolonged service in the office or other outpatient setting; additional 30 minutes) (list separately in addition to code for prolonged service) Primary Care G0438 (annual wellness visit, initial visit) G0439 (annual wellness visit, subsequent visit) (chronic care management NOT specifically telehealth) (was GXXX1)
34 CCM Chronic Care Management chronic care management services furnished to patients with 2 or more chronic conditions expected to last at least 12 months, or until the death of the patient, that place the patient at significant risk of death, acute exacerbation or decompensation, or functional decline Pt must be enrolled and engage in care planning Must use MU certified (or equivalent) registry/system 20 minutes or more; billable once every 30 days Any staff with indirect supervision from clinician Proposed reimbursement rate: $42.60/month
35 Implications of Not designated as telehealth but many telehealth services meet billing requirements Will drive Expansion of many telehealth services (monitoring) Primary Care redesign efforts Expansion of ACOs Commercial payer reimbursement for same services The overall shift from inpatient to outpatient services that is required for successful population health management
36 Michigan Reimbursement Michigan Medicaid reimburses for live video: Consults, office visits Individual psychotherapy, pharmacologic management End stage renal disease (ESRD) related services. However, there must be at least one in person visit per month, by a physician, nurse practitioner, or physician's assistant, to examine the vascular site for ESRD services. Where face to face visits are required, telemedicine services may be used in addition to the required face to face visit, but cannot be used as a substitute. Medicaid Provider Manual, p (Oct. 1, 2012).
37 Michigan Reimbursement The following health professionals may provide telemedicine services: Physician, Osteopath, Podiatrist (MD, DO, DPM) Nurse practitioner, physician's assistant, (billed under the supervising physician) Nurse midwife Psychologist, Social worker (must be billed by PIHP/CMHSP, FQHC, or THC) No remote surgical procedures or robotics Medicaid Provider Manual, p (Oct. 1, 2012).
38 Michigan Reimbursement Originating site facility fee paid to authorized originating sites: County or publicly funded mental health facility FQHC, RHC, THC Any hospital Any health practitioner s office Renal dialysis facility Skilled nursing facility MDCH Bulletin: MSA (April 1, 2006).
39 Michigan Medicaid Policy 34_432621_7.pdf
40 Michigan Medicaid Policy 34_432621_7.pdf
41 Michigan Medicaid Policy 34_432621_7.pdf
42 Michigan Medicaid Policy 34_432621_7.pdf
43 MI Medicaid Reimbursement Table _42542_42543_42546_ ,00.html
44 Michigan Medicaid Reimbursement The 50 mile rule has been eliminated As of October 1, 2013, there are no geographic restrictions on telemedicine reimbursement Telemedicine services included in MI Medicaid Expansion (effective in 2014)
45 TM Commercial Parity Law 2012 MI HB 5408 prohibits a group or nongroup health care corporation from requiring face to face contact between a health care provider and a patient for service appropriately provided through telemedicine MI HB 5421 prohibits health maintenance organizations and individual contracts from requiring faceto face contact between a health care provider and a patient for services appropriately provided through telemedicine. Effective 7/18/2012
46 Michigan Reimbursement Medicaid Reimbursement Amounts by CPT elemedicine _409374_7.pdf
47 Outline Intro to UMTRC and National TRC Program Telehealth as a Component of Your Clinical Business Billing for Services Provided via Telehealth Questions 47
48 QUESTIONS Jonathan Neufeld, PhD, HSPP Clinical Director Upper Midwest Telehealth Resource Center (574)
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