A Discussion on Telehealth Changes and Vaccine Billing
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When it comes to telehealth, in 2020 so many things changed and we continue to see changes into 2021. While some changes are designated as temporary; others such as the expansion of certain telehealth services may be here to stay. During this presentation, we’ll discuss the changes in telemedicine as a result of COVID-19; what was included in temporary Social Security Act section 1135 waivers and what telemedicine services are expected to remain after the public health emergency is officially over. We’ll then move on to a more recent challenge with COVID-19 vaccines. We’ll review the vaccines approved for Emergency Use Authorization, and discuss billing guidelines from CMS. Whether your organization is PPS, CAH, FQHC, RHC or IHS, during this information-packed webinar, we will be addressing vaccine billing guidance for all facility types.
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A Discussion on Telehealth Changes and Vaccine Billing
- 1. Click to edit Master title style COVID-19 Telehealth & Vaccines: What you need to know hrgpros.com Developed by Megan Smith Executive Director of Quality and Training msmith@hrgpros.com 509.824.1715
- 2. Discussion Topics hrgpros.com • Telehealth Expansion – What’s Staying/Going • Impact of PHE expiration • COVID-19 vaccine billing
- 3. hrgpros.com Telehealth During COVID-19 PHE 144 Services Added 24.5M Visits Mar-Oct 2020 RHC, FQHC, provider home as Distant Site OK Patient’s home as originating site New or established OK Telehealth Before COVID-19 PHE 107 billable services Approx. 15,000 visits weekly Originating & distance site restrictions Established patient restriction ____________________________________________________________ Source: CMS Newsroom, December 1, 2020 Press Release; https://www.cms.gov/newsroom/press-releases/trump-administration-finalizes-permanent-expansion-medicare-telehealth- services-and-improved-payment
- 4. Future of Telehealth • Published 12/1/2020 for 2021 CY • 251 total services • Telehealth services split into 3 groups based on an expiration date • Commissioned study of telehealth flexibilities provided during COVID- 19 PHE hrgpros.com
- 5. GROUP A • Effective 1/1/2021 • Permanent addition - No expiration • 112 or 45% of telehealth services • Including: group psycho- therapy (90853), neurobehavioral status exams (96121), short home visits (99347-99348), visit complexity add-on code for certain E&Ms (G2211) hrgpros.com Source: HealthManagement.com.; December 14, 2020; CMS Finalizes Meaningful Expansions of Medicare Telehealth Service Coverage Through 2021; https://www.healthmanagement.com/blog/cms-finalizes- meaningful-expansions-of-medicare-telehealth-service-coverage-through-2021/
- 6. GROUP B • Effective 1/1/2021 • Expires end of calendar year after pandemic ends • 57 or 23% of telehealth services • Incl. ED visits (99281-99285), PT/OT/SP (all levels), discharge day management (99238-99239), critical care services (99291-99292) • Data gathering for potential 2022 coverage hrgpros.com Source: HealthManagement.com.; December 14, 2020; CMS Finalizes Meaningful Expansions of Medicare Telehealth Service Coverage Through 2021; https://www.healthmanagement.com/blog/cms-finalizes- meaningful-expansions-of-medicare-telehealth-service-coverage-through-2021/
- 7. GROUP C • Effective 1/1/2021 • Expires end of PHE • 82 or 33% of telehealth services • Incl. audio-only, initial hospital and nursing home visits for new patients • Indicated as Temporary Addition for the PHE for the COVID-19 Pandemic on 2021 Medicare Telehealth list of services hrgpros.com Source: HealthManagement.com.; December 14, 2020; CMS Finalizes Meaningful Expansions of Medicare Telehealth Service Coverage Through 2021; https://www.healthmanagement.com/blog/cms-finalizes- meaningful-expansions-of-medicare-telehealth-service-coverage-through-2021/
- 8. Remote Patient Monitoring • Consent at time of service • Auxiliary clinical personnel can provide RPM services Communication Technology Based Services (CTBS) • G2252 Longer audio-only visits • Expansion of billable providers Incident-to Billing • Direct supervision of clinic staff via interactive audio-video Nursing Facility Care • Limit reduced to once every 14 days from once every 30 days hrgpros.com
- 9. Impact of PHE Expiration hrgpros.com • Audio-only visits no longer covered • Distant & Originating site restrictions re-engaged • Telehealth once again limited to established patients • List of covered telehealth services reduced by 82 • Including developmental screenings, inpatient vent management, cardiac rehab, initial observation or hospital care, speech therapy
- 10. EUA Explained Emergency Use Authorization (EUA) Mechanism to facilitate the availability and use of medical countermeasures, including vaccines, during public health emergencies • Emergency use of unapproved medical products • Unapproved uses of approved medical products Criteria: • No adequate, approved and available alternatives • Clinical trials conducted under FDA standards hrgpros.com
- 11. Pfizer – BioNTech COVID-19 Vaccine • FDA EUA 12/11/2020 • Ages 16+ • 2 Dose, 21 Day Interval • Vaccine code 91300 • Admin: 0001A (1st dose) 0002A (2nd dose) • NDC 59267-1000-1 • (10 digit) • 59267-1000-01 • (11 digit) Moderna COVID- 19 Vaccine • FDA EUA 12/18/2020 • Ages 18+ • 2 Dose, 28 Day Interval • Vaccine code 91301 • Admin: 0011A (1st dose) • 0012A (2nd dose) • NDC 80777-273-10 • (10 digit) • 80777-0273-10 • (11 digit) Janssen COVID-19 Vaccine • FDA EUA 2/27/2021 • Ages 18+ • 1 Dose • Vaccine code 91303 • Administration: 0031A • NDC 59676-580-005 • (10 digit) • 59676-0580-05 • (11 digit) AstraZeneca, Plc COVID-19 Vaccine •Not FDA Approved •2 Dose, 28 Day Interval •Vaccine code 91302 •Administration: 0021A (1st dose); 0022A (2nd dose) •NDC 0310-1222-10 •(10 digit) •00310-1222-10 •(11 digit) ` hrgpros.com
- 12. Vaccine Documentation • Each recipient’s vaccination should be recorded in the patient’s record within 24 hours of administration and include: • Vaccine and date of administration, manufacturer, lot number, vaccination site and route, name and title of the person administering the vaccine • Vaccination record card given to the vaccine recipient should include: • Date of vaccination, product name/manufacturer, lot number, and name/location of the administering clinic or healthcare professional hrgpros.com ____________________________________________ Source: Centers for Disease Control and Prevention; COVID-19 Vaccination; https://www.cdc.gov/vaccines/covid-19/
- 13. Vaccine Reporting • All COVID-19 vaccination providers must report vaccine inventory daily into VaccineFinder • Inventory Reporting • Share Vaccinating Locations • Report the vaccination to the appropriate state/local Immunization Information System (IIS) hrgpros.com ____________________________________________ Source: Centers for Disease Control and Prevention; COVID-19 Vaccination; https://www.cdc.gov/vaccines/covid-19/
- 14. CDC Recommendations Pfizer BioNTech and Moderna Vaccines • Not interchangeable; both doses of the series should be completed with the same product • Schedule appointment for second dose before vaccine recipient leaves • Distribute COVID-19 vaccination record cards and encourage patients to bring card to appointment for second dose • Enroll in a free smartphone-based tool that uses text messaging and web surveys to provide personalized health check-ins as well as second-dose reminders hrgpros.com ____________________________________________________ Source: Centers for Disease Control and Prevention; Vaccines & Immunizations page; https://www.cdc.gov/vaccines/covid-19/info-by-product/clinical-considerations.html
- 15. hrgpros.com Roster Billing OP Department IP Hospital ESRD Facility Home Health Agency CORF IHS Facility CAH Physician, Non- physician, Pharmacy, Mass Immunizer
- 16. Roster Billing Details • Part A roster billing includes roster and individual claim information keyed into DDE • TOB depends on facility type (example: 12X hospital inpatient, 34X Home Heath, etc.) • Revenue code should be 0771 • Reminder: vaccines are billed/reimbursed separately from inpatient charges • Physician, non-physician, pharmacy and Mass Immunizer bill using 1500 claim, POS 60 (except RHC or FQHC) hrgpros.com
- 17. FQHC & RHC Federally Qualified Health Centers • Must submit claim to report HCPCS for both COVID-19 vaccine and administration • TOB 77X, revenue codes 0771 Administration | 0636 Vaccine • HCPCS considered informational only • Reimbursed via cost report like flu and pneumococcal vaccines Rural Health Clinic • Reported on cost report like flu and pneumococcal vaccines • Vaccine and administration payment based on reasonable cost through cost report hrgpros.com
- 18. Skilled Nursing Facility • Vaccine administered by Skilled Nursing Facility is billed to Medicare by SNF • External provider under contract under SNF; vaccine billed by SNF to Medicare Mass Immunizers • PHE allows Medicare-enrolled immunizers, including pharmacies, to bill directly and receive direct reimbursement from Medicare hrgpros.com _______________________________________________________ Source: SNF: Enforcement Discretion Relating to Certain Pharmacy Billing; https://www.cms.gov/medicare/covid-19/snf-enforcement-discretion-relating-certain-pharmacy-billing
- 19. CMS Vaccine Billing Tips • Medicare FFS handling reimbursement for Medicare managed care plans • No patient cost share for vaccine • Bill administration only - do not include vaccine on claim when federally supplied • Although not preferred – vaccine with $0.01 charge will be accepted on claim hrgpros.com
- 20. Vaccine Cost Sharing hrgpros.com • Must administer COVID-19 Vaccine at no out-of-pocket cost to the recipient • May not deny anyone vaccination based on the vaccine recipient’s coverage status or network status • May not charge an office visit or other fee if COVID-19 vaccination is the sole medical service provided • May not require additional medical services to receive COVID-19 vaccination • May seek appropriate reimbursement from a program or plan that covers COVID-19 Vaccine administration fees for the vaccine recipient, such as: • Vaccine recipient’s private insurance company • Medicare or Medicaid reimbursement • HRSA COVID-19 Uninsured Program for non-insured vaccine recipients __________________________________________________ Source: CDC COVID-19 Vaccine Program Provider Requirements and Support; https://www.cdc.gov/vaccines/covid-19/vaccination-provider-support.html#
- 21. hrgpros.com BioFire Respiratory Panel 2.1 (RP2.1) • Emergency Use Authorization - 2020 • CPT 0202U, effective 5/20/2020 • Not covered by CMS, effective 1/1/2021 • Non-covered under most commercial • Check policies – keywords: • Lab, Nucleic Acid, Molecular Diagnostic
- 22. Resource Links • March 15th Section 1135 Waiver declaration https://www.phe.gov/emergency/news/healthactions/section1135/Pages/covid19 -13March20.aspx • Public Health Emergency Declarations https://www.phe.gov/emergency/news/healthactions/phe/Pages/default.aspx • CMS 1135 Waiver Details: https://www.cms.gov/Medicare/Provider-Enrollment- and-Certification/SurveyCertEmergPrep/1135-Waivers • Vaccine Fact Pages: Pfizer, Moderna, AstraZeneca, Janssen • AMA Appendix Q: https://www.ama-assn.org/system/files/2021-01/covid-19- immunizations-appendix-q-table.pdf hrgpros.com
- 24. hrgpros.com