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When it comes to urgent care billing, one of the biggest challenges centers face is keeping up with changes – from regulatory agencies to patient demands. In this installment of 3 Things to Know About RCM, we’ll cover changing codes and modifiers that popped up late in 2021, how the Office of the Inspector General is looking at telehealth, and elevating your documentation game by using a scribe in your urgent care practice.

What’s New in 2022

The Centers for Medicare & Medicaid Services (CMS) added a new Place of Service (POS) at the very end of 2022. New POS 10 is for “Telehealth Provided in Patient’s Home”. The description for POS 02 has been revised to “Telehealth Provided Other than in Patient’s Home”. The new POS will not be available for use until April 1, 2022.

Although the POS Workgroup created this code, Medicare said they do not have a use for it. While they will accept it for claims processing because it’s required under HIPAA, urgent care providers should continue to use the current Medicare billing instructions for telehealth claims.

New ICD-10 Codes & Modifier

Starting on April 1, 2022, you can start using the three new ICD-10 codes that were also added:

  • 310 Unvaccinated for COVID-19
  • 311 Partially vaccinated for COVID-19
  • 39 Other under-immunization status

Code Z18.310 should be assigned when the patient has not received at least one dose of any COVID-19 vaccine. Code Z28.311 may be assigned when the patient has received at least one dose of a multi-dose COVID-19 vaccine regimen but has not received the full set of doses necessary to meet the Centers for Disease Control and Prevention (CDC) definition of “fully vaccinated” in place at the time of the encounter. These new codes should not be used until April 1, 2022.

Finally, new modifier 93 (Synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system) became effective January 1, 2022. Use this modifier for those payers that want phone calls billed with an E/M code instead of CPTs 99441-99443.

Experity will continue to monitor the guidance for use of these new codes.

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Take Note Now of These OIG Work Plans Surrounding Telehealth

Add “telefraud’ to your compliance lingo dictionary

During the COVID-19 pandemic public health emergency (PHE), the industry experienced significant growth in telehealth. Unfortunately, fraud and other nefarious schemes kept pace. The Office of Inspector General (OIG) is looking at telehealth claims submitted to Medicare and Medicaid with scrutiny and many providers may be directly affected. Once the PHE ends, some federal agencies may not continue current telehealth policies due to extensive “telefraud” resulting from this expansion.

According to industry insiders, the OIG discovered it’s easy to for unscrupulous actors and those with the inclination to conduct sham remote visits to increase the size and scale of their telehealth operations. As a result, the OIG will be looking closely at these six focus areas:

1. Home Health and Home Care Services

For agencies that provided skilled services via telehealth during the PHE, audits will focus on making an early assessment to determine whether skilled services provided during the PHE were furnished via telehealth and whether the services were administered and billed according to Medicare requirements. The face-to-face component of home health services doesn’t include telehealth – and this requirement may be one reason for scrutiny by OIG

2. Medicare Part B Telehealth Services

The OIG will be conducting audits in two phases. In Phase 1 audits, the OIG will determine whether evaluation and management (E/M) services, opioid use disorder, end-stage renal disease, and psychotherapy met the Medicare requirements. In the Phase 2 audits, the OIG will look at telehealth services related to distant and originating site locations, virtual check-in services, electronic visits, remote patient monitoring, and the use of telehealth technology.

Specifically – they will be looking at how practices billed audio-only services and wellness visits performed via telehealth.

3. Home Health Agencies Strategies and Challenges Responding to COVID-19 Pandemic

The OIG will look at the strategies home health agencies (HHAs) navigated while responding to the challenges presented by COVID-19. This report will look at how agencies dealt with staffing issues, telehealth implantation, and how and whether agencies’ emergency preparedness plans translated to actual preparedness.

4. Medicare Telehealth Service During COVID-19 Pandemic Program Integrity Risks

The OIG is going to analyze services’ billing patterns for telehealth services and find key characteristics of providers that pose a program integrity risk to Medicare. It’s likely the OIG will focus on practices coding level 5 and a variety of inconsistencies.

5. Use of Medicare Telehealth Services During the COVID-19 Pandemic

As the pandemic ramped up, CMS cut a lot of red tape surrounding telehealth, making it easier for beneficiaries to access services without having to risk an in-person encounter. CMS is considering making some of these adjustments permanent.

The OIG says it’s going to review telehealth service data from Medicare Parts B and C during the pandemic. The work plan “will look at the extent to which telehealth services are being used by Medicare beneficiaries, how the use of these services compares to the use of the same services delivered in person, and the different types of providers and beneficiaries using telehealth services,” the OIG says.

The OIG is evaluating whether beneficiaries can access the same quality of care via telehealth, and, if not, why there might be a payment parity, Fletcher notes.

6. Medicaid Telehealth Expansion During COVID-19 Emergency

The OIG is looking to see how states managed rapid and perhaps unanticipated expansion of telehealth services for state Medicaid programs, and how state agencies and their oversight of these programs fared.

“Our objective is to determine whether State agencies and providers complied with Federal and State requirements for telehealth services under the national emergency declaration, and whether the States gave providers adequate guidance on telehealth requirements,” the OIG says.

Use This Opportunity as a Check-In

This is a good time to take a look at how your practice managed telehealth growth, billing and coding to determine whether or not you have proper policies in place and be sure you’re compliant.

While telehealth will never replace all face-to-face encounters, patient demand may have practices considering expanding the use of telehealth. It’s a great time to evaluate whether telehealth is a good fit for your urgent care.

Can a Virtual Scribe Work for Your Practice?

Weigh the pros and cons

Using a scribe may be appealing to multiple stakeholders in your urgent care practice. It allows the clinician to focus on the patient rather than note-taking during an encounter without sacrificing thorough documentation of the patient’s health record.

If you’re considering using a scribe, consider these points–especially if you’re considering a virtual scribe. Clinicians may find virtual scribes especially appealing as the pandemic rages on, as the virtual connection removes one additional source of exposure.

Don’t Forget About HIPAA

If you’re considering hiring a virtual scribe, you don’t necessarily have to advertise and hire an individual. Companies exist to connect practices with these services; you can research and contract with a company rather than a “freelance” individual. Plus, an established company that is reputable has the benefit of ensuring compliance with the Health Insurance Portability and Accountability Act (HIPAA).

When using a virtual scribe, the encounter is not recorded, but there is someone on the other end of a microphone listening in on everything. Some companies even do it with AI, so it’s a computer program listening, not a human. Any reputable company providing this service will be HIPAA-compliant,” she says.

Prioritize the Patient’s Perspective

During the pandemic, some patients may be especially worried about “unnecessary” sources of exposure and may view an in-person scribe with skepticism or outright distrust. However, patients may also be skeptical of a virtual scribe, wondering who is listening to their appointment, where the person is located, whether the encounter is being recorded or simply streamed live, and whether their privacy is maintained.

Many people may be more comfortable with an in-person scribe because it erases those questions. But comfort level may be affected by how “embarrassing” the reason for the visit.

It’s important to weigh these considerations when making a decision for you and your patients.

Aim for Transparency

Transparency builds and maintains trust, and patients probably want to know who can access their health information. Consent and informed consent are crucial aspects of any clinician-patient interaction and making sure the patient feels comfortable with everyone in the room (literally or figuratively) is important.

Technically, physicians may not have to tell patients that they’re relying on transcription, rather than personally taking notes. Patient consent is not likely required by law, but the company providing the service needs to have a contract with the provider or practice.

Once you sort out the nitty-gritty details of transparency surrounding the encounter itself, you’ve done the hard work; you don’t need to worry about the documentation itself. And as long as it’s signed by the clinician, it doesn’t really matter how the documentation got in the chart and medical record.

Interested in more urgent care tips, best practices, and industry updates? Check out our December and January installments.

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