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Expansion of Telehealth with 1135 Waiver

Under this new waiver, Medicare can pay for office, hospital, and other visits furnished via telehealth across the country, including in patients’ places of residence, starting March 6, 2020. A range of providers, such as doctors, nurse practitioners, clinical psychologists, and licensed clinical social workers, will be able to offer telehealth to their patients.  Additionally, the HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.

Prior to this waiver, Medicare could only pay for telehealth on a limited basis:  when the person receiving the service is in a designated rural area and when they leave their home and go to a clinic, hospital, or certain other types of medical facilities for the service.

Virtual Check-ins

  • Virtual check-in services can only be reported when the billing practice has an established relationship with the patient.
  • This is not limited to only rural settings or certain locations.
  • Individual services need to be agreed to by the patient; however, practitioners may educate beneficiaries on the availability of the service prior to patient agreement.
  • HCPCS code G2012: Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.
  • HCPCS code G2010: Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment.
  • Virtual check-ins can be conducted with a broader range of communication methods, unlike Medicare telehealth visits, which require audio and visual capabilities for real-time communication.

E-Visits

  • These services can only be reported when the billing practice has an established relationship with the patient.
  • This is not limited to only rural settings. There are no geographic or location restrictions for these visits.
  • Patients communicate with their doctors without going to the doctor’s office by using online patient portals.
  • Individual services need to be initiated by the patient; however, practitioners may educate beneficiaries on the availability of the service prior to patient initiation.
  • The services may be billed using CPT codes 99421-99423 and HCPCS codes G2061-G206, as applicable.
  • The Medicare coinsurance and deductible would generally apply to these services.

Health Insurance Portability and Accountability Act (HIPAA)

Effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency. For more information: https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/index.html

If you have any questions or would like to speak to our healthcare consultants, please contact your Blue & Co. advisor today.

Click here to see our full chart of services, HCPCS/CPT Codes, and patient relationship with provider in relation to service type.

For additional information, please visit the following websites:

General Provider Telehealth and Telemedicine Tool Kit

IHCP Bulletin from March 19, 2020 (Specifically for Indiana Medicaid Providers)


Please continue to monitor our Coronavirus Resources and Information Page and COVID-19 Relief & Operations FAQs for updates.

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