QUESTION: We run an acute care hospital. In order to prevent the spread of COVID-19, we have allowed some of our practitioners to provide services to Medicare beneficiaries via telehealth. These Medicare beneficiaries are receiving services in their homes that they would normally receive in the hospital’s outpatient department. What does the recent interim final rule from CMS say about the practitioner’s ability to bill for this sort of arrangement?
ANSWER: Effective March 1, 2020, when a practitioner who ordinarily practices in a hospital outpatient department furnishes a telehealth service to a patient who is located at home, they may submit a professional claim with the place of service code indicating that the service was furnished in the hospital’s outpatient department. Medicare will then pay the practitioner under the Physician Fee Schedule at the facility rate (as though the service had been provided in the hospital’s outpatient department).
The interim final rule contains further details about the hospital’s ability to bill for its services. To access the interim final rule, click here. For a general overview of recent Medicare telehealth developments, click here.
QUESTION: In an effort to manage exposure during the COVID-19 pandemic, we are trying to expand the use of telehealth throughout our system. Do we need to grant “telemedicine privileges” to Medical Staff members who have already been credentialed and privileged before the pandemic started if they are now using telehealth to treat patients remotely? We are Joint Commission accredited.
ANSWER: This question seems to be coming up a lot. Fortunately, The Joint Commission has given out some good guidance on how to handle this issue during the COVID crisis. In an FAQ document, The Joint Commission has advised:
“Licensed Independent Practitioners (LIP) CURRENTLY credentialed and privileged by the organization, who would now provide the same services via a telehealth link to patients, would not require any additional credentialing or privileging. The medical staff determines which services would be appropriate to be delivered via a telehealth link. There is no requirement that ‘telehealth’ be delineated as a separate privilege.” (Emphasis added.)
This Standards FAQ can be found here.
In light of this guidance, there does not appear to be a need to grant telemedicine privileges to physicians or other practitioners who have already been granted clinical privileges simply because they are now delivering services via telehealth. In light of the statement that the “medical staff determines which services would be appropriate to be delivered via a telehealth link,” it may be prudent to have your MEC weigh in on what services can be provided in this fashion.