Expansion of Telehealth a Potential Savior for Providers Reeling Financially from Pandemic

Reimbursement for such services has grown during recent weeks.

Many healthcare entities are facing tough economic times. There is a possible solution that benefits patients while also providing revenue that may help healthcare organizations survive. 

Send something to all patients explaining that they can use telehealth for nearly all visits during the COVID-19 emergency. People are avoiding necessary medical care out of fear of contracting the virus, so you will be helping patients and your organization by educating patients about telehealth options. Your organization has the option of waiving the co-payment and deductible for Medicare patients. (That waiver is not required, but it is allowed.) It is wise to inform patients whether they will be responsible for a co-payment when they schedule the appointment.

Telehealth is presenting a raft of challenges for everyone, including insurers. Last week I was working with a health system trying to comply with billing guidance from private insurers. A highly impressive compliance professional was able to assemble a chart listing each payer and its instructions for telehealth billing during the COVID-19 crisis. 

The inconsistencies were mind-boggling. I’ll limit this discussion to place of service (POS). A few of the insurers were gracious enough to defer to Medicare policy, indicating that the POS should be location the patient would have presented. But some specifically wanted POS 2, telehealth. Others wanted the location of the patient. They recommended using 12, home, unless the patient was in a facility like an assisted living facility, in which case 13 would be used. One insurer, oddly, wanted the physician’s location to control. If the physician was at home, 12 would be used. If the physician was in the office, 11 would be appropriate. Maybe I’m just not smart enough, but I can’t understand how anyone could develop a system to comply with these disparate instructions. In particular, how does one bill a claim when there is coverage from two insurers with differing expectations?

I think it’s great that the insurers are quickly adapting to a changing environment and are willing to cover telehealth. I recognize that each needed to develop instructions, and there is no mechanism for them to easily coordinate. But it isn’t realistic for healthcare organizations to implement these widely variant instructions. 

So, what do you do? My advice would be to develop a very friendly letter, saying something like:

Dear Insurer: We really appreciate the speed with which you agreed to cover telehealth services. As you may know, billing instructions from different insurers vary considerably. Because it’s not realistic for us to implement these conflicting instructions, we are going to use the approach recommended by Medicare. We will list the place of service on the claim that they would have been used, absent the COVID-19 emergency. If the patient would have presented in the office, we will use POS 11. Since this should have no impact on reimbursement, we hope you will understand this decision. If you have any concerns, please let me know.

Such a letter should eliminate any risk that an accusation of fraud arises. It also seems unlikely to stir the wrath of a payer. Just be reasonable, friendly, clear, and firm.

This approach doesn’t result in a guarantee that the payer will process your claim. But it seems like a practical, reasonable approach that balances the insurer’s needs with yours. 

Programming Note: David Glaser is a permanent panelist on Monitor Mondays. Listen to his live reporting every Monday at 10-10:30 a.m. EST.


David M. Glaser, Esq.

David M. Glaser is a shareholder in Fredrikson & Byron's Health Law Group. David assists clinics, hospitals, and other health care entities negotiate the maze of healthcare regulations, providing advice about risk management, reimbursement, and business planning issues. He has considerable experience in healthcare regulation and litigation, including compliance, criminal and civil fraud investigations, and reimbursement disputes. David's goal is to explain the government's enforcement position, and to analyze whether this position is supported by the law or represents government overreaching. David is a member of the RACmonitor editorial board and is a popular guest on Monitor Mondays.

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