What We Know Today 3-27-20

Confusion prevails...

When the President and CMS announced that many telehealth restrictions were being waived, our first thought was “great, the removal of barriers and red tape will make this transition easier” and in some ways it did. But I actually think it made the system even more complicated while moving more physicians and patients into using it.

Before this started, there were established guidelines with each carrier, including Medicare, that were spelled out… either get on board or don’t. Today that has all changed. (Backing up for a second, I do believe this is a good thing and we’ll all be better off for it so please don’t take my words negatively on this subject). Three weeks ago if you called Medicare to ask about delivering and coding for telehealth, the answer would have been the same with each CSR you spoke with. Today, if you speak with 10 CSRs you’ll probably get 5 different answers, and considering we have multiple Medicare intermediaries throughout the country, that number is likely higher.

The same goes for private and state payors as well. We’ve seen conflicting information about the address in box 32 of the CMS1500, conflicting information in use of POS, and conflicting information in the use of modifiers… all within the same private payor. If you’re confused, believe me so are the payors, and they will be for several more weeks. I’m not an insurance fan but they can’t just flip a switch and change how claims are processed. Shirley Gill Walker expressed that point on our podcast as she has worked on the carrier side and seen the complexity first-hand… I truly trust her insight. We’re also noticing varying benefits within the same payor in different parts of the country. I have no idea why that may be and hopefully alignment will occur soon.

There’s also a separate issue on the practice side and that’s the staffs ability to interpret the information receive. For many, eligibility is received electronically and telehealth is not showing up in the patients benefits. Again, this may take some time to normalize. Others are calling and misinterpreting what they hear. One post stated the carrier has waived all copays, coinsurances, and deductibles however the writer was livid and couldn’t understand why insurances were expecting providers to not collect and absorb this loss (if you’re not following the misunderstanding here then we really need to talk).

I don’t blame CMS, I don’t blame private payors, and I don’t blame staff with limited knowledge. It was a huge change of policy in a very short time that has sent demand over the top.

So what do we do? My recommendation is DO NOT OVERTHINK and OVERCOMPLICATE this matter. If you place too many variables into every payor and every claim you create, you’ll not have a baseline to make adjustments for rebills and appeals. You will be incredibly overwhelmed. I’ll place a link below for a guideline to follow or if you already have one STAY WITH IT. Use the guide to send your first set of claims and watch the EOBs closely as soon as they come in. Adjust your coding to unsent claims, by payor, and immediately isolate your AR for payors that deny based on claim information. It will either be box 32, POS, or the modifier combination.

One exception for the link I’m posting is that Medicare has now stated that a modifier is not required. The 02 POS code is their indicator that the visit was delivered as telehealth.


One last item to mention… some billers are hearing that a provider must update his/her practice location to his/her home address if the provider performs the telehealth service from that point. Maybe yes, maybe no… don’t panic thinking you now have to wait 3 months to bill because credentialing is slowed… do the best you can under the circumstances we are in. Many of us believe we will be operating in a state of forgiveness for a while. And as information begins to settle out and normalize, it will be your responsibility to make adjustments to credentialing elements and begin to fall in line with each carrier’s policy. We are going to make mistakes, carriers are going to make mistakes… the key at this time is to show your intent is in good faith and you are working diligently to adjust as you learn.