 Provider News GeorgiaOctober 2022 Anthem Provider News - GeorgiaIf you disagree with the outcome of a claim, you may begin the Anthem Blue Cross and Blue Shield (Anthem) provider claims dispute process. The simplest way to define a claim dispute is when the claim is finalized, but you disagree with the outcome.
For more information on the claim dispute process, please see the table in the attached PDF titled Anthem provider claims dispute process.
It’s important to note that providers and facilities will not be penalized for filing a claim payment dispute.
Attend a training webinar
For step-by-step instructions about how to submit a claim payment dispute through Availity, register for training by logging onto Availity.com > Help & Training > Get Trained > Select the session most convenient for you. Self-guided training is also available through Get Trained.
For a more detailed explanation of our claims payment dispute and clinical appeal process, please review the Provider Manual.
Now open for learning!
Understanding how to use the many time saving applications on Availity Essentials* is important to working together digitally. Anthem Blue Cross and Blue Shield has developed a learning place just for that purpose — the Provider Learning Hub.
Using the Provider Learning Hub available from https://www.anthem.com/provider is the easiest and quickest way to access courses and learning guides about claim submission, attachments and status, eligibility and benefits, and more.
These new and improved learning experiences apply to Availity Essentials and electronic data interchange (EDI) transactions:
- Visit the Provider Learning Hub for short, easy-to-follow training videos with supporting resources — no username and password required.
- Handy filtering options make it easy to find what you are looking for.
- The Favorites folder lets you save courses for easy access later.
- Register once and on future visits your preferences are populated, eliminating the need for any additional logon information.
Get started today!
Access the Provider Learning Hub today using this link or from https://www.anthem.com/provider under Important Announcements on the home page.
We are asking you to review your online provider directory information on a regular basis to ensure it is correct. Access your information by visiting www.anthem.com, select For Providers, then choose Go To Providers Overview, select Find Care.
Submit updates and corrections to your directory information using our online Provider Maintenance Form. Online update options include:
- Add/change an address location.
- Name change.
- Tax ID changes.
- Provider leaving a group or a single location.
- Phone/fax number changes.
- Closing a practice location.
Once you submit the form, we will send you an email acknowledging receipt of your request.
The Consolidated Appropriations Act (CAA) contains a provision that requires online provider directory information be reviewed and updated (if needed) at least every 90 days. By reviewing your information regularly, you can help us ensure your online provider directory information is current.
Material adverse change
The following services will be added to prior authorization for GA local members for the effective dates listed below.
Eligibility and benefits can be verified by accessing Availity* via the Anthem Blue Cross and Blue Shield (Anthem) provider website or by calling the number on the back of the member’s identification card. Service preapproval is based on the member’s benefit plan/eligibility at the time the service is reviewed/approved. Benefit plans vary widely and are subject to change based on the contract effective dates. The provider is responsible for verification of member eligibility and covered benefits.
Except in the case of an emergency, failure to obtain approval prior to rendering the designated services listed below may result in denial of reimbursement.
Criteria
|
Criteria description
|
Code
|
Effective date
|
SURG.00120
|
Internal rib fixation systems
|
21811
|
Add 01/01/2023
|
SURG.00120
|
Internal rib fixation systems
|
21812
|
Add 01/01/2023
|
SURG.00120
|
Internal rib fixation systems
|
21813
|
Add 01/01/2023
|
SURG.00116
|
High resolution anoscopy screening for anal intraepithelial neoplasia (AIN) and squamous cell cancer of the anus
|
46601
|
Add 01/01/2023
|
SURG.00116
|
High resolution anoscopy screening for anal intraepithelial neoplasia (AIN) and squamous cell cancer of the anus
|
46607
|
Add 01/01/2023
|
TRANS.00011; TRANS.00013
|
Pancreas transplantation and pancreas kidney transplantation; small bowel, small bowel/liver and multivisceral transplantation
|
48551
|
Add 01/01/2023
|
TRANS.00011; TRANS.00013
|
Pancreas transplantation and pancreas kidney transplantation; small bowel, small bowel/liver and multivisceral transplantation
|
48552
|
Add 01/01/2023
|
TRANS.00011
|
Pancreas transplantation and pancreas kidney transplantation
|
48556
|
Add 01/01/2023
|
SURG.00036
|
Fetal surgery for prenatally diagnosed malformations
|
59076
|
Add 01/01/2023
|
SURG.00144
|
Occipital nerve block therapy for the treatment of headache and occipital neuralgia
|
64405
|
Add 01/01/2023
|
LAB.00027
|
Selected blood, serum and cellular allergy and toxicity tests
|
83516
|
Add 01/01/2023
|
CG-LAB-13
|
Skin nerve fiber density testing
|
88356
|
Add 01/01/2023
|
CG-ANC-04
|
Ambulance services: air and water
|
A0430
|
Add 01/01/2023
|
CG-ANC-04
|
Ambulance services: air and water
|
A0431
|
Add 01/01/2023
|
CG-ANC-04
|
Ambulance services: air and water
|
A0435
|
Add 01/01/2023
|
CG-ANC-04
|
Ambulance services: air and water
|
A0436
|
Add 01/01/2023
|
CG-DME-44
|
Electrical nerve stimulation, transcutaneous, percutaneous
|
A4555
|
Add 01/01/2023
|
RAD.00064
|
Myocardial sympathetic innervation imaging with or without single-photon emission computed tomography (SPECT)
|
A9582
|
Add 01/01/2023
|
RAD.00036
|
MRI of the breast
|
C8903
|
Add 01/01/2023
|
RAD.00036
|
MRI of the breast
|
C8905
|
Add 01/01/2023
|
RAD.00036
|
MRI of the breast
|
C8906
|
Add 01/01/2023
|
RAD.00036
|
MRI of the breast
|
C8908
|
Add 01/01/2023
|
DME.00037
|
Cooling devices and combined cooling/heating devices
|
E0217
|
Add 01/01/2023
|
CG-DME-44
|
Electrical nerve stimulation, transcutaneous, percutaneous
|
E0766
|
Add 01/01/2023
|
SURG.00036
|
Fetal surgery for prenatally diagnosed malformations
|
S2401
|
Add 01/01/2023
|
SURG.00036
|
Fetal surgery for prenatally diagnosed malformations
|
S2402
|
Add 01/01/2023
|
SURG.00036
|
Fetal surgery for prenatally diagnosed malformations
|
S2403
|
Add 01/01/2023
|
SURG.00036
|
Fetal surgery for prenatally diagnosed malformations
|
S2404
|
Add 01/01/2023
|
SURG.00036
|
Fetal surgery for prenatally diagnosed malformations
|
S2405
|
Add 01/01/2023
|
SURG.00036
|
Fetal surgery for prenatally diagnosed malformations
|
S2409
|
Add 01/01/2023
|
CG-ANC-04
|
Ambulance services: air and water
|
S9960
|
Add 01/01/2023
|
CG-ANC-04
|
Ambulance services: air and water
|
S9961
|
Add 01/01/2023
|
We understand that submitting authorizations by phone or fax is time consuming and inefficient. We have a digital application, Interactive Care Reviewer (ICR), that makes it easy to submit, review, and check authorization status all in one place, electronically.
We’d like to invite you to a webcast that covers how to:
- Access ICR
- Create an authorization request
- Inquire on a previously submitted authorization
- Update a case
- Copy a case
- View letters associated with a case
- Request and check the status of an authorization appeal
Join us for an ICR learning webcast:
Wednesday, October 12, 2022, at 11 a.m. Eastern time
Register here
Visit the ICR Target page to register and to access self-service learning by viewing recorded learning sessions. Download ICR user guides and other job aides from the ICR Target page too. You can also register from the Provider Learning Hub by clicking on the ICR live webinar learning icon.
This communication applies to the Commercial and Medicare Advantage programs from Anthem Blue Cross and Blue Shield (Anthem).
Care providers are a trusted resource for members when it comes to vaccine advice. As information on the monkeypox outbreak changes and vaccination and testing guidance is released, we’re committed to keeping you informed.
Some care providers may have seen a message on their provider Explanation of Benefits (EOB) stating that Anthem does not recognize the vaccine product codes for monkeypox and smallpox that became effective July 26, 2022. We’re updating the provider fee schedules to reflect the new vaccine product codes as quickly as possible. The EOB message did not impact payment for administration of the vaccines, which is reimbursable; however, since the monkeypox and smallpox vaccines are provided by the government at no charge, the vaccine products are non-reimbursable.
To aid in processing claims for the monkeypox and smallpox vaccine products, care providers must include these three elements on claims, even if vaccine products were received from the federal government at no charge:
- Product code (90611 or 90622)
- Applicable ICD-10-CM diagnosis code
- Administration code
More detail on codes and cost-sharing
Providers are encouraged to use:
- Product code 90611 for smallpox and monkeypox vaccine.
- Product code 90622 for vaccinia (smallpox) virus vaccine.
- Code 87593 for laboratory testing.
When billing the monkeypox and smallpox vaccine products, care providers should submit those codes with a $0.01 charge.
Cost-sharing for the vaccine is waived.
If you have any questions, contact the Provider Service number on the back of the member’s ID card. You can read more information on monkeypox here.
The Medical Policy and Technology Assessment Committee (MPTAC) adopted the attached new and/or revised medical policies and clinical guidelines. Some may have expanded rationales, medical necessity indications or criteria and some may involve changes to policy position statements that might result in services that previously were covered being found to be either not medically necessary or investigational/not medically necessary. Clinical guidelines adopted by Anthem Blue Cross and Blue Shield and all the medical policies are available on the Anthem provider website. Please note our medical policies now include NOC (not otherwise classified) codes to expedite the process of determining services that may require medical review. If you don’t have access to the internet, you may request a hard copy of a specific medical or behavioral health policy or clinical UM guideline by calling provider services at (800) 241-7475 Monday–Friday from 8:00 a.m. to 7:00 p.m. Or send written requests (specifying medical policy or guideline of interest, your name and address to where information should be sent) to:
Anthem Blue Cross and Blue Shield
Attention: Prior approval, mail code GAG009-0002
3350 Peachtree Road NE
Atlanta, GA 30326
NOTE: Any clinical guideline included in this standard MPTAC notification is only effective for Georgia if included on the Georgia standard adopted clinical guideline list unless there is a group-specific review requirement in which case it will be considered ‘adopted’ for that group only and for the specific type of review required. Additionally, as part of the pre-payment review program for commercial or Federal Employee Health Benefits Program (FEHBP) plans, clinical guidelines approved by MPTAC but not included in the Georgia standard adopted clinical guideline list may be used to review a provider’s claims when a provider’s billing practices are not consistent with other providers in terms of frequency or in some other manner or for provider education and are “adopted” for those purposes.
Open the attached document titled GA medical policy and clinical guideline updates 10.1.2022 to view the new and/or revised medical policies and clinical guidelines adopted by the MPTAC.
To view medical policies and utilization management guidelines applicable to members enrolled in the Blue Cross and Blue Shield Service Benefit Plan (commonly referred to as the Federal Employee Program® (FEP®)), please visit fepblue.org > policies & guidelines.
Effective as of July 27, 2022, Anthem Blue Cross and Blue Shield combined the Three-Dimensional (3D) Radiology Services- Facility and Three-Dimensional (3D) Radiology Services - Professional policies into a single policy. The Three-Dimensional (3D) Radiology Services - Professional policy was updated to include the facility-specific language from the facility policy, and the title was changed to Three-Dimensional (3D) Radiology Services – Professional and Facility. As a result, the Three-Dimensional (3D) Radiology Services - Facility policy will be retired.
For specific policy details, visit the reimbursement policy page at Anthem.com provider website.
Beginning with dates of service on or after January 1, 2023, Anthem Blue Cross and Blue Shield will update the Related Coding section of the policy with the following:
- Added CPT code 43497 to base code 43235 Esophagogastroduodenoscopy (EGD) with the reduction of 100% primary and 25% subsequent
For specific policy details, visit the reimbursement policy page at anthem.com.
Effective July 8, 2022, Federal Employee Program (FEP) for Anthem Blue Cross and Blue Shield (Anthem) began participating in a real-time provider chat option through Availity Essentials. The secure portal allows providers to seek real-time answers to questions about prior authorization, precertification requirements, status check, and more.
Currently, only Missouri and Georgia providers can access the chat capability for Federal members. Chat is available from 8 a.m. to 7 p.m. ET through the secure provider website found at www.availity.com. Select Payer Spaces, Anthem, and access the chat through Chat with Payer.
Chat is one example of how FEP is using digital technology to improve the health care experience with the goal of saving valuable time.
With the success of the real-time chat option for Federal members, Anthem is implementing additional states ranging in dates from October 2022 through the first quarter of 2023.
October 2022 – Colorado, Connecticut, and Ohio.
December 2022 – Indiana, Maine, Nevada, and Virginia.
February 2023 – Kentucky, New Hampshire, New York, and Wisconsin.
Visit the Drug Lists page on https://www.anthem.com for more information on:
- Copayment/coinsurance requirements and their applicable drug classes
- Drug lists and changes
- Prior authorization criteria
- Procedures for generic substitution
- Therapeutic interchange
- Step therapy or other management methods subject to prescribing decisions
- Any other requirements, restrictions, or limitations that apply to using certain drugs
The Commercial and Exchange drug lists are posted to the website quarterly on the first day of the month in January, April, July, and October.
To locate Exchange Select Formulary and pharmacy information, scroll down to Select Drug Lists. This drug list is also reviewed and updated regularly as needed.
Federal Employee Program (FEP) pharmacy updates and other pharmacy related information may be accessed at www.fepblue.org > Pharmacy Benefits.
This communication applies to the Commercial and Medicare Advantage programs from Anthem Blue Cross and Blue Shield (Anthem) in Georgia.
Our pharmacy benefit management partner, IngenioRx,* will join the Carelon family of companies and change its name to CarelonRx on January 1, 2023.
This change will not affect the ways in which CarelonRx will do business with care providers and there will be no impact or changes to the prior authorization process, how claims are processed, or level of support.
If your patients are having their medications filled through IngenioRx’s home delivery and specialty pharmacies, please take note of the following information:
- IngenioRx Home Delivery Pharmacy will become CarelonRx Mail.
- IngenioRx Specialty Pharmacy will become CarelonRx Specialty Pharmacy.
These are name changes only and will not impact patients’ benefits, coverage, or how their medications are filled. Your patients will not need new prescriptions for medicine they currently take.
When e-prescribing orders to the mail and specialty pharmacies:
- Prescribers will need to choose CarelonRx Mail or CarelonRx Specialty Pharmacy, not IngenioRx, if searching by name.
- If searching by NPI (National Provider Identifier), the NPI will not change.
In addition to the mail and specialty pharmacies, your patients can continue to have their prescriptions filled at any in-network retail pharmacy.
Keeping you well informed is essential and remains our top priority. We will continue to provide updates prior to January and throughout 2023.
Material adverse change
Specialty pharmacy updates for Anthem Blue Cross and Blue Shield (Anthem) are listed below.
Prior authorization clinical review of non-oncology use of specialty pharmacy drugs is managed by Anthem’s medical specialty drug review team. Review of specialty pharmacy drugs for oncology use is managed by AIM Specialty Health® (AIM), a separate company.
Inclusion of National Drug Code (NDC) code on your claim will help expedite claim processing of drugs billed with a Not Otherwise Classified (NOC) code.
Step therapy updates
Effective for dates of service on and after January 1, 2023, the following specialty pharmacy codes from current or new clinical criteria documents will be included in our existing specialty pharmacy medical step therapy review process.
Please note that infliximab agents are subject to step therapy today and this is to notify of the changes in the preferred and non-preferred products. Inflectra will become non-preferred and Avsola will become preferred as of January 1, 2023.
Access our Clinical Criteria to view the complete information for these step therapy updates.
Clinical Criteria
|
Status
|
Drug
|
HCPCS or CPT Code(s)
|
ING-CC-0062
|
Preferred
|
Avsola
|
Q5121
|
ING-CC-0062
|
Preferred
|
Infliximab Unbranded
|
J1745
|
ING-CC-0062
|
Preferred
|
Remicade
|
J1745
|
ING-CC-0062
|
Non-preferred
|
Inflectra
|
Q5103
|
ING-CC-0062
|
Non-preferred
|
Renflexis
|
Q5104
|
Effective for dates of service on and after January 1, 2023, the following Clinical Criteria were developed and might result in services that were previously covered but may now be found to be not medically necessary.
ING-CC-0219
|
Korsuva (difelikefalin acetate)
|
Access the Clinical Criteria document information.
Anthem Blue Cross and Blue Shield’s medical specialty drug review team will manage prior authorization clinical review of non-oncology specialty pharmacy drugs. Drugs used for the treatment of Oncology will be managed by AIM Specialty Health® (AIM).*
Medicare Advantage
Consultation codes will no longer be allowed for Anthem Blue Cross and Blue Shield for Medicare Advantage. This determination aligns with CMS guidance and does not allow reimbursement for inpatient (99251-99255) or outpatient (99241-99245) consultation codes and requires providers to bill the appropriate office visit evaluation and management (E/M) code for consultation services.
Medicare Advantage
Material adverse change (MAC)
Effective for dates of service on and after December 1, 2022, the specialty Medicare part B drug listed in the table below will be included in our precertification review process.
Federal and state law, as well as state contract language and CMS guidelines, including definitions and specific contract provisions/exclusions, take precedence over these precertification rules and must be considered first when determining coverage. Noncompliance with new requirements may result in denied claims.
HCPCS or CPT® codes
|
Medicare part B drugs
|
J3490, J3590
|
Amvuttra (vutrisiran)
|
J3299
|
Xipere (triamcinolone acetonide injectable suspension)
|
Medicare Advantage
(Policy 21-001, effective 01/01/2022)
In the October 2021 edition of the provider newsletter, we announced that a new reimbursement policy titled Sexually Transmitted Infections Testing — Professional would be effective for dates of service on or after January 1, 2022. We have made a decision to retract this reimbursement policy.
If you have any questions, contact your Provider Experience associate or visit the Contact Us page on our provider website (https://www.anthem.com/medicareprovider) for up-to-date contact information.
Medicare Advantage
Material adverse change (MAC)
Effective for dates of service on and after December 1, 2022, the specialty Medicare Part B drug listed in the table below will be included in our precertification review process. Federal and state law, as well as state contract language and CMS guidelines, including definitions and specific contract provisions/exclusions, take precedence over these precertification rules and must be considered first when determining coverage. Noncompliance with new requirements may result in denied claims.
HCPCS or CPT® codes
|
Medicare Part B drugs
|
C9399, J3490, J3590, J9999
|
Alymsys (bevacizumab-maly)
|
This FAQ communication is designed to provide general guidance for questions related to Medicare telehealth services during the Coronavirus (COVID-19) Public Health Emergency (PHE). The PHE is ongoing and ever evolving; therefore, Anthem Blue Cross and Blue Shield (Anthem) wants to support accurate and up-to-date information around legal and regulatory changes that may impact healthcare.
This FAQ is for informational purposes only and is intended to provide guidance regarding the changing landscape of Medicare telehealth. This guidance is not all-inclusive; it is intended to address frequently asked questions and common Medicare telehealth topics. The content included herein is not intended to be a substitute for the provisions of applicable statutes or regulations or other relevant guidance issued by CMS, as those items are subject to change from time-to-time.
General
Q. What virtual services are categorized as telehealth?
According to CMS, there are three main types of virtual services that physicians and other qualified healthcare providers can render to Medicare beneficiaries: (i) Medicare telehealth visit; (ii) virtual check-ins; and (iii) e-visits. Medicare telehealth visits are those facilitated by a telecommunication system between a provider and a patient. Virtual check-ins, which may or may not be face-to-face, are brief (5 to 10 minutes) interactions with an established patient and provider via telephone or other telecommunications platform and are used to determine whether an office visit or other service is needed. E-visits are non-face-to-face, patient-initiated communications between an established patient and their provider through an online patient portal. Please refer to the CMS Telemedicine Fact sheet for additional information.
Medicare Telehealth Services
|
Virtual Service
|
Description of Virtual Service
|
Medicare Covered
|
Eligible for
Risk Adjustment Payment
|
Place of Service (POS)
|
Telehealth visits with real-time, interactive simultaneous audio and video
|
Medicare telehealth visits with real-time, interactive simultaneous audio and video are treated the same as an in-person visit and can be billed using the code for that service; POS 02 for telehealth provided at a location other than the patient’s home, or POS 10 for telehealth provided in the patient’s home; and telehealth CPT modifier 95 to indicate the services were performed via audio-visual telehealth
|
YES
|
YES
|
POS 02 or 10 (depending on location) and telehealth CPT modifier 95
|
Telehealth visits with audio only
|
Certain Medicare telehealth services may be conducted via an audio-only telecommunications system and can be billed using the code for that service; any applicable POS; and telehealth CPT modifier 93 to indicate the services were performed via audio only telehealth
See CMS List of Telehealth Services
|
YES
|
NO
|
Any applicable POS and telehealth CPT modifier 93
|
Virtual/brief
check-ins
|
5-to-10-minute communication with an established patient to determine the need for an in-person visit
|
YES
|
NO
|
Any applicable POS
|
E-visit
|
Communication between an established patient and their provider through an online patient portal
|
YES
|
NO
|
Any applicable POS
|
Q: According to CMS, what types of services may be offered via telehealth?
As a result of the COVID-19 public health emergency (PHE), CMS has expanded the types of services that may be offered via telehealth. A complete list of Medicare telehealth services payable under the Medicare Physician Fee Schedule can be found here: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.
Q: Who may perform telehealth services?
In accordance with the Social Security Act and CMS guidance, healthcare professionals such as physicians, nurse practitioners, physician assistants, certified registered nurse anesthetists, certified nurse-midwives, clinical social workers, clinical psychologists, and registered dietitians may perform and bill for acceptable telehealth services within their scope of practice and consistent with federal and state requirements. For more information, please view the Social Security Act and the CMS List of Telehealth Services.
Q: Can telehealth services be rendered using FaceTime?
Yes, CMS has eased some Health Insurance Portability and Accountability Act (HIPAA) Privacy rules and currently permits the use of telecommunications systems that have audio and video capabilities that allow for simultaneous real-time, interactive communication between a healthcare provider and a patient. During the COVID-19 PHE, the Department of Health & Human Services (HHS) has waived penalties for HIPAA violations, allowing healthcare providers to serve patients using communications technologies, like FaceTime or Skype, when used in good faith. The Department of Health & Human Services (HHS) addresses telehealth remote communications in the Notification of Enforcement Discretion for Telehealth.
Q: Can any of the services on the Medicare telehealth list be furnished and billed when rendered using audio-only technology, such as a telephone?
Currently, and throughout the duration of the PHE, eligible providers may furnish certain limited services using audio-only technology. These services are included on the Medicare telehealth list. Unless this list indicates that a service is acceptable for delivery through audio-only interaction, the Medicare telehealth service must be furnished simultaneously using, at a minimum, an interactive audio and video telecommunications system that permits real-time communication between the provider and patient.
Telephonic-only (in other words, telephone) evaluation and management (E/M) service provided by a physician or other qualified healthcare professional to an established patient, parent, or guardian (not originating from a related E/M services provided within the last seven days nor leading to an E/M service or procedure within the next 24 hours) should be billed with codes 99441-99443.
Q: Is occupational therapy considered a covered Medicare telehealth service?
Historically, therapy services, such as occupational therapy, have not been included on the list of approved Medicare telehealth services. However, in light of the public health emergency (PHE) associated with the COVID-19 pandemic, CMS offered additional clarification in the interim final rule and March 17, 2020 Medicare Provider FAQ. There, CMS acknowledged the need to mitigate exposure risks during the PHE by adding therapy services to the telehealth list as of March 1. Importantly, only eligible healthcare providers may render such services.
While practitioners such as physical therapists, occupational therapists, and speech-language pathologists are not among those identified under section 1842(b)(18)(C) of the Social Security Act as eligible to furnish and bill for Medicare telehealth services, such providers are permitted to offer virtual check-ins (G2010 and G2012) and remote evaluations (in other words, e-visits (G2061-G2063)), and telephone E/M services (98966-98968), where appropriate.
Q: Does a healthcare provider have to be licensed in the state in which the patient is located at the time of service?
As a result of the COVID-19 PHE, many states have relaxed licensing requirements to support continuity of care and prevent impediments to accessing care during these unprecedented times. Further, on March 13, 2020, pursuant to the 1135-based waivers, CMS temporarily waived requirements that out-of-state healthcare providers must be licensed in the state in which they are providing services as well as the state in which they practice. More specifically, CMS will waive this licensing requirement when the following criteria is met: (i) provider is enrolled in the Medicare program; (ii) provider has a valid license to practice in the state associated with their Medicare enrollment; (iii) state in which provider is practicing – in addition to that associated with their Medicare enrollment – is affected by the COVID-19 PHE; and (iv) provider is not affirmatively barred from practice in the state in which they seek to render services or any other state that is part of the 1135 emergency area. Therefore, if the above criteria are met, providers may practice in states other than that in which they are licensed to practice if the state in which the provider wishes to practice via telehealth has – like CMS – waived its licensure requirements. Because licensure and scope of practice laws vary from state to state, it is important to check the applicable state-specific requirements and a member’s benefit agreement.
For additional information on the 1135 Waiver, please consult the Waiver or Modification of Requirements under Section 1135 of the Social Security Act from the US Department of Health and Human Services.
Billing and documentation guidance:
Q: What place of service (POS) code should be used for telehealth services rendered during the PHE?
To report telehealth E/M services to Anthem for a real-time, interactive simultaneous audio and video encounter, the applicable E/M CPT code, CPT Telehealth modifier 95, and either POS 02 or POS 10, depending on the location of the patient at the time of service should be used.
Importantly, CPT Telehealth modifier 95 must be used to indicate the encounter as an audio and video, real-time, interactive interaction between a provider and a patient. CPT Telehealth modifier 93 must be used to indicate the encounter as an audio only interaction between a provider and a patient.
Q: Is the originating site restriction still in place for Medicare telehealth visits?
No, under section 1834(m)(4)(C) of the Social Security Act, Medicare telehealth visits must meet strict originating site requirements (both geographic and site of service restrictions). Statutory originating sites include locations such as physician or practitioner office, hospital, skilled nursing facility, among other healthcare facilities. However, in the interim final rule, CMS lifted these restrictions for services beginning March 6, 2020, and for the duration of the COVID-19 PHE. There, CMS authorized qualified healthcare providers to render telehealth services to patients wherever they are located, including the patient’s home.
Q: Are there specific documentation requirements for telehealth services during the PHE?
Healthcare providers should document services furnished via telehealth the same way a face-to-face encounter would be documented, except for the elements that require the presence of the patient, in other words, physical examination. Additionally, providers should document that the service was rendered via telehealth to reflect details of the encounter accurately and completely, specifically indicating whether the telehealth visit was with audio and video or whether it was audio only. See above regarding Q&A as to coding guidance, for example, E/M, POS, and CPT Telehealth modifier.
Q: Can an annual wellness visit (AWV) be conducted and billed for when rendered via telehealth even when vitals cannot be captured?
Yes, as of April 30, 2020, CMS expanded the list of acceptable Medicare telehealth services to include the AWV (G0438, Initial AWV and G0439, Subsequent AWV). Though several of the required elements of an AWV look and feel the same when completed via telehealth, some, like recording a patient’s vitals, necessitate adaptation. Healthcare providers should continue to document all information accurately and completely what they are able to collect during a telehealth encounter. Therefore, the provider can ask the patient if they have the ability to measure their height, weight, temperature, blood pressure, and/or heart rate. If so, the patient may be able to do so during the telehealth encounter. Alternatively, the patient may be able to self-report such information; self-reported information should be documented as such.
However, if vitals cannot be captured during a telehealth AWV, an AWV may still be conducted and billed when rendered in accordance with state and federal guidelines. In the interim final rule, CMS provided additional flexibility to providers during the COVID-19 PHE: on an interim basis, CMS removed requirements regarding documentation of history and/or physical exam in the medical record for office/outpatient evaluation and management (E/M) encounters provided via telehealth.
Medicare Risk Adjustment (MRA or risk adjustment)
Q: Is a diagnosis code reportable for risk adjustment purposes if documented by a provider based on a telehealth encounter?
As of the April 10, 2020, Memo, and as confirmed in the updated January 15, 2021, Memo, CMS authorizes Medicare Advantage organizations (MAOs) to submit diagnoses for risk adjustment from telehealth encounters, only when those encounters meet all criteria for risk adjustment data submission. More specifically, diagnoses submitted for risk adjustment purposes from a telehealth encounter must meet the following requirements:
- Encounter must be face-to-face, using interactive audio telecommunication simultaneously with video telecommunication to permit real-time communication between the provider and the member;
- Provider must use CPT Telehealth modifier 95;
- Provider must use POS 02 for telehealth provided at a location other than the patient’s home or POS 10 for telehealth provided in the patient’s home;
- Services rendered must be those which are allowable by CMS, included within the Anthem benefit package, and clinically appropriate to furnish via a face-to-face telehealth encounter;
- Provider must be an acceptable physician specialty/provider type, for example, physician (MD or DO), physician assistant (PA), or nurse practitioner (NP); and
- Encounter must meet all other criteria for risk adjustment eligibility, which include, but are not limited to, being from an allowable inpatient, outpatient, or professional service.
Q: How can the risk adjustment face-to-face requirement be met for services rendered via telehealth?
As a result of the COVID-19 PHE, CMS expanded the definition of face-to-face with regard to risk adjustment data submission criteria. Formerly, this requirement was met only when an in-person encounter between a patient and an acceptable provider type/physician specialty occurred. Under its April 10, 2020, guidance, CMS authorized satisfaction of this required element in a virtual setting via telehealth. To meet the risk adjustment face-to-face requirement for telehealth encounters, CMS requires the provider to simultaneously use an interactive audio and video telecommunications system that permits real-time communication between the provider and patient.
Q: Do telephone (audio-only) encounters between a provider and patient satisfy CMS criteria for risk adjustment payment?
No, an audio-only encounter, such as that facilitated using telephone audio-only, does not satisfy the criteria for risk adjustment data eligibility. To satisfy the criteria for risk adjustment data submission, diagnoses submitted based on a telehealth encounter must be derived from an eligible face-to-face interaction between a provider and patient. More specifically, the interaction must be conducted in real-time with simultaneous use of an interactive audio and video telecommunication system.
Q: How should a real-time, interactive audio and video telehealth encounter be reported?
To report telehealth Evaluation and Management (E/M) services to Anthem for an audio and video encounter, please use applicable E/M CPT code, CPT Telehealth modifier 95, and either POS 02 or POS 10 depending on the location of the patient at the time of service. CPT Telehealth modifier 95 in addition to the applicable POS must be used so Anthem can identify the encounter as an eligible face-to-face telehealth encounter, in other words, one that took place via real-time, simultaneous interactive audio and video telecommunications system. Providers should also document that the service was rendered via telehealth to reflect details of the encounter accurately and completely, specifically indicating that the telehealth visit was performed with audio and video.
Q: Would an encounter using Skype meet the CMS face-to-face requirement for risk adjustment data submission?
Yes, CMS currently permits the use of telecommunications systems with audio and video capabilities that allow for simultaneous, real-time, interactive communication between a healthcare provider and a patient. During the COVID-19 PHE, penalties for HIPAA violations have been waived. This waiver allows providers to serve patients using communications technologies like Skype or FaceTime when used in good faith. The department of Health and Human Services (HHS) addresses telehealth remote communications in the Notification of Enforcement Discretion for Telehealth.
Q: To what dates of service (DOS) is the CMS guidance applicable with regard to eligible interactive audio and video telehealth encounters for risk adjustment payment?
During an April 29, 2020, stakeholder call, CMS clarified to what DOS its April 10, 2020, guidance regarding the applicability of diagnoses from telehealth services for risk adjustment data submission and payment applied. There, CMS stated that such guidance is applicable to eligible face-to-face telehealth encounters (in other words, those using real-time, interactive audio simultaneously with video) within open data submission periods, which as of the date of publication of this document include 2019 DOS, 2020 DOS, 2021 DOS, and 2022 DOS.
|