Posted: 05/16/2023

Telehealth Post PHE Updates

As you are no doubt aware, the Public Health Emergency (PHE) ended on May 11, 2023.  The use of telemedicine services was expanded under the COVID-19 pandemic; however, with the end of the PHE, the guidelines and applicability for use of telemedicine services has been scaled back by the insurance carriers.

Below are some of the more common Frequently Asked Questions we are getting regarding changes to telemedicine. 

At the end, we will have links to the policies for each of the payers; if your question is not answered in the FAQ, please review the link to the insurance company.  If you still cannot find your answer, please reach out to Melissa Kirshner (mkirshner@cmstpa.com) or Kelly Shew (kshew@cmstpa.com) and we will assist you.

Frequently Asked Questions

Can I still do telemedicine visits?
Yes, you can still perform telemedicine visits.  Most insurances are continuing to pay for both video visits (CPT codes 99212-99215) and audio-only visits (CPT codes 99441-99443) for established patients through 2024.  You may want to verify the patient’s individual policy to confirm their coverage.

What do I need to document for a telehealth visit?
In addition to your regular documentation for a visit, you should continue to include a statement that addresses these 4 key pieces of information:

• Location of the provider during the telehealth visit (ex: home, office, etc).
• Location of the patient during the telehealth visit (ex: home, office, city/state, etc).
• Use of audio/visual (video visit) or audio-only (telephone visit) equipment.
• The patient gives their consent to receive treatment using this method.

Please note: we fully expect to start seeing audits of telemedicine visits in the next year or two.  Chart notes that do not include the above 4 pieces of information will not pass audit and will be recouped by the carriers.

Are there any restrictions on what type of remote communication technology/platform I can use for telehealth visits?
Yes.  The platform that you use for telehealth visits now MUST be HIPAA compliant.  This was strongly recommended, but not required, during the PHE.  If you are using platforms like Facebook Live, Zoom/GoTo Meetings/Teams/WebEx (non-healthcare accounts), etc, stop immediately and switch to a HIPAA compliant platform.

Some suggestions of HIPAA compliant platforms include: Doxy.me, Vidyo, InTouch, BlueJeans, or Zoom for Healthcare.  If you are currently using an EHR (EPIC, eClincalWorks, etc), the video software embedded in it should be compliant.

What place of service should I report for telehealth visits?

• POS 02: Telehealth provided other than in patient's home. Use this when the patient is not located in their home when receiving health services or health related services through telecommunication technology.
• POS 10: Telehealth provided in patient's home. Use this place of service when the patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology.

I currently supervise other practitioners, which I have been able to do either in person or virtually during the pandemic.  Has this changed?
Yes.  Now that the PHE has ended, pre-PHE rules are in effect.  You must be immediately available on-site and within the “4 walls” of the office when supervising other practitioners.

Link to Insurance Company Policies

BCBS / BCN Michigan
HAP
Humana
Medicaid
Medicare
Priority Health

More info:
Telehealth.HHS.gov
Telehealth Services After the PHE (Article)
When the PHE Ends, so Do These Medicare Waivers (Article)