Provider Updates and FAQs

Updated March 23, 2020

The distant site is the location where the provider is located at the time a service is provided via telemedicine. The originating site is the location of the patient during a telemedicine visit.

Updated May 5, 2020

COVID-19 Update: During the COVID-19 PHE, Medicare distant site telehealth services can be furnished by any health care practitioner working for an RHC or FQHC within their scope of practice. Effective March 1, 2020, CMS is waiving the requirements of section 1834(m)(4)(E) of the Act and 42 CFR § 410.78 (b)(2) which specify the types of practitioners that may bill for their services when furnished as Medicare telehealth services from the distant site. The waiver of these requirements expands the types of health care professionals that can furnish distant site telehealth services to include all those that are eligible to bill Medicare for their professional services. As a result, a broader range of practitioners, such as physical therapists, occupational therapists, and speech language pathologists can use telehealth to provide many Medicare services.

Each licensing board (LSBME, Board of Nursing, etc.) defines if their providers can provide services via telemedicine. Billing for Medicare telehealth services is limited to professional services delivered by the following providers: Physicians, Nurse Practitioners, Physician Assistants, Nurse Midwives, Certified Nurse Specialists, Certified Registered Nurse Anesthetists, Clinical Phycologists, Clinical Social Workers, and Registered Dieticians or Nutrition Professionals. Louisiana Medicaid does not limit the providers that may provide services via telemedicine.

Updated April 17, 2020

COVID-19 UPDATE: Included in the recent coronoavirus stimulus bill (HR 748: Coronoavirus Aid, Relief, and Economic Security Act), which was passed and signed by the president on 3/27/2020,  is a provision to allow RHCs and FQHCs to serves as the distant site for telemedicine services during the COVID-19 emergency period. RHCs and FQHCs can now provide services to Medicare patients via telemedicine after 3/27/2020 for the duration of the COVID-19 emergency.

For both Medicare and Louisiana Medicaid, there is no restriction on the location of the provider when services are rendered via telemedicine. However, Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) do not qualify to bill as distant sites under Medicare. RHCs and FQHCs can bill as the distant site under Louisiana Medicaid.

Updated March 23, 2020

COVID-19 UPDATE: The Medicare restriction on the originating site is temporarily lifted in response to the COVID-19 event. Effective for services starting March 6, 2020 and for the duration of the COVID-19 Public Health Emergency, Medicare will make payment for Medicare telehealth services furnished to patients in all areas of the country in all settings (including any healthcare facility and the patient’s home, regardless of rural/urban designation).

Normally for Medicare reimbursement, the patient must be located in a rural (non-metropolitan statistical area) health professional shortage area (HPSA) and in an eligible facility at the time of services. Eligible facilities are: provider offices, hospitals, critical access hospitals, rural health clinics, federally qualified health centers, skilled nursing facilities, community mental health centers, and hospital-based or CAH-based renal dialysis centers.

Under normal circumstances, Louisiana Medicaid does not restrict the location of the patient during a telemedicine visit. The originating site can include, but is not limited to, a healthcare facility, school, or the patient’s home.

Updated May 5, 2020

COVID-19 UPDATE: Effective for dates of service on or after March 5, 2020, Medicaid will allow the use of telemedicine/telehealth to perform clinically appropriate components of Early and Periodic Screening, Diagnostic and Treatment (EPSDT) preventive services (well-child care) for members older than 24 months of age.  Please see the current version of Informational Bulletin 20-5 for more information.

Effective for dates of service on or after March 23, 2020, Medicaid will reimburse dentists for the use of teledentistry, when appropriate, for rendering emergency dental services.  Please see the current version of Informational Bulletin 20-11 for more information.

For dates of service beginning March 1, 2020 through the end of the COVID-19 emergency, Medicare has approved several new codes to be billed via telemedicine. As of April 30, 2020 (retroactive for dates of service on or after March 1, 2020) this list also indicates which services can be furnished and reimbursed via audio-only when live audio-visual connection is not available.

For dates of service on or after March 17, 2020, and for the duration of the COVID-19 emergency, Louisiana Medicaid has expanded coverage for several Physical, Occupational, and Speech Therapy services provided via telemedicine. Effective for dates of service March 21, 2020, has also expanded coverage for mental health services provided via telemedicine. Please review the Medicaid Informational Bulletins for more information.

Medicare published the list of codes that are reimbursable when provided via telemedicine.

When otherwise covered by Louisiana Medicaid, telemedicine/telehealth is allowed for all CPT codes located in Appendix P of the CPT manual. These codes include, but are not limited to, new and established outpatient office visit codes.

Updated March 23, 2020

Qualifying sites (see above) may bill Medicare as the originating site. Originating sites should bill for HCPCS code Q3014 (originating site facility fee) and utilize the Place of Service code “02” to indicate that the service was provided via telemedicine. The current reimbursement rate is approximately $26.00.

Louisiana Medicaid does not reimburse the originating site.

Updated May 6, 2022

COVID-19 UPDATE: Effective March 6, 2020, physicians and practitioners who bill for Medicare telehealth services provided to patients outside of a qualifying originating site (ex: at home), can report the POS code that would have been reported had the service been furnished in person (i.e. the physician office). This will allow the provider to receive reimbursement for the PFS non-facility rate (if applicable). The “-95” modifier should be appended to services provided via telemedicine. (Note: Claims will not be denied if billed under the normal telemedicine billing process using the place of service of “02” but will be reimbursed at the PFS facility rate rather than the non-facility rate.)

For Medicare services furnished beginning on March 1, 2020, during the COVID-19 PHE, CMS will pay all of the reasonable costs for any service related to COVID-19 testing, including applicable telehealth services. For Medicare services related to COVID-19 testing, including telehealth, providers must waive the collection of co-insurance from beneficiaries. For services in which the coinsurance is waived, providers must put the “CS” modifier on the service line.  Claims with the “CS” modifier will be paid with the coinsurance applied, and the Medicare Administrative Contractor (MAC) will automatically reprocess these claims beginning on July 1. Coinsurance should not be collected from beneficiaries if the coinsurance is waived.

Effective for dates of service on or after March 17, 2020, outpatient hospital facilities must bill telehealth claims using the normal revenue code and applicable procedure code with modifier “-95” appended. (The POS 02 telehealth guidance for professional claims does not apply for telehealth billing on the UB 04 Form).

Medicare only reimburses professional services provided via telemedicine. When billing for services provided via telemedicine (live audio and video), the appropriate CPT/HCPCS code for services provided should be utilized. Place of Service code of “02” should be utilized to indicate that the service was provided via telemedicine. The “-GT” modifier should be appended to the relevant codes if billing under CAH Option Payment Method II.

For Medicaid, when billing on Form 1500, providers must indicate the appropriate Place of Service 02 (other than home) or 10 (home), based on the patient’s location at the time of service. The “-95” modifier should also be appended on all detailed service lines to indicate that the service was provided via telemedicine.

Updated February 26, 2021

COVID-19 UPDATE: Per the CARES Act, RHCs and FQHCs can now serve as the distant site for Medicare telehealth visits. Billing and reimbursement guidance was issued by CMS via MLN Matters Article Number SE20016, revised on February 23, 2021. For telehealth distant site services furnished between January 27, 2020, and June 30, 2020, RHCs must report HCPCS code G2025 on their claims with the CG modifier. Modifier “95” (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) may also be appended, but is not required. Beginning July 1, 2020, RHCs should no longer put the CG modifier on claims with HCPCS code G2025.

For telehealth distant site services furnished between January 27, 2020, and June 30, 2020, that are also FQHC qualifying visits, FQHCs must report three HCPCS/CPT codes for distant site telehealth services: the FQHC Prospective Payment System (PPS) specific payment code (GO466, G0467, G0468, G0469, or G0470); the HCPCS/CPT code that describes the services furnished via telehealth with modifier 95; and G2025 with modifier 95. When furnishing services via telehealth that are not FQHC qualifying visits, FQHCs should hold these claims until July 1, 2020, and then bill them with HCPCS code G2025. Modifier 95 may be appended but it is not required. Beginning July 1, 2020, FQHCs will only be required to submit G2025. Modifier 95 may be appended but it is not required.

For services furnished on March 18, 2020 through the duration of the COVID-19 PHE, CMS will pay all of the reasonable costs for specified categories of evaluation and management (E/M) services if they result in an order for or administration of a COVID-19 test and relate to the furnishing or administration of such test or to the evaluation of an individual for purposes of determining the need for such test. This would include applicable telehealth services. See MLN Matters article SE20011 for more information—revised on November 9, 2020. For the specified E/M services related to COVID-19 testing, including when furnished via telehealth, RHCs and FQHCs must waive the collection of co-insurance from beneficiaries. For services in which the coinsurance is waived, RHCs and FQHCs must put the “CS” modifier on the service line. For preventive services that are furnished via telehealth and have cost-sharing waived, RHCs must report G2025 on their claims with the CG and CS modifier and FQHCs must report G2025 with the CS modifier on or after July 1, 2020 RHC and FQHC claims with the “CS” modifier will be paid with the coinsurance applied, and the Medicare Administrative Contractor (MAC) will automatically reprocess these claims beginning on July 1, 2020. Coinsurance should not be collected from beneficiaries if the coinsurance is waived.

When billing Medicaid for services provided via telemedicine (live audio and video), providers must indicate the appropriate Place of Service 02 (other than home) or 10 (home), based on the patient’s location at the time of service. For Medicaid, when billing on the Form 1500, the “-95” modifier should also be appended to all relevant CPT codes to indicate that the service was provided via telemedicine.

Updated April 14, 2020

COVID-19 UPDATE: Effective March 6, 2020, physicians and practitioners who bill for Medicare telehealth services provided to patients outside of a qualifying originating site (ex: at home), can report the POS code that would have been reported had the service been furnished in person (i.e. the physician office). This will allow the provider to receive reimbursement for the PFS non-facility rate (if applicable). The “-95” modifier should be appended to services provided via telemedicine. (Note: Claims will not be denied if billed under the normal telemedicine billing process using the place of service of “02” but will be reimbursed at the PFS facility rate rather than the non-facility rate).

For both Medicare and Medicaid, telemedicine visits (live audio and video) are considered the same as in-person visits and are paid at the same rate as regular, in-person visits. For Medicare, a private practice provider is paid the PFS facility rate and the originating site is paid a facility fee.

Updated February 26, 2021

COVID-19 UPDATE: For Medicare telehealth distant site services furnished between January 27, 2020 and June 30, 2020, RHCs will be paid at their all-inclusive rate (AIR), and FQHCs will be paid based on the FQHC Prospective Payment System (PPS) rate. These claims will be automatically reprocessed in July when the Medicare claims processing system is updated with the distant site telehealth services rate. RHCs and FQHCs do not need to resubmit these claims for the payment adjustment.  RHCs/FQHCs with a per-visit rate below the distant site telehealth services rate will receive an additional payment reflecting the difference between their AIR/PPS rate and the distant site telehealth services rate. For RHCs/FQHCs with an AIR/PPS rate above the telehealth payment rate, CMS will RECOUP the difference.

Medicare telehealth distant site services furnished between July 1, 2020, and the end of the COVID-19 PHE,  will be paid at the new distant site telehealth services rate.

For Medicare telehealth services with cost-sharing waived, the telehealth payment rate for RHCs and FQHCs will be $99.45. (See MLN SE20011 for more information cost-sharing related to COVID-19 testing) For Medicare telehealth services with cost-sharing applied (i.e. not waived), the coinsurance for these services will be 20% of the lesser of the allowed amount ($99.45) or actual charges, and the payment will be 80% of the lesser of the allowed amount ($99.45) or the actual charges. Before the adjustment, the coinsurance for distant site services furnished was 20% of the actual charges and the payment was the allowed amount ($99.45) minus the coinsurance. MACs will automatically reprocess any claims with HCPCS code G2025 for services furnished on or after January 27, 2020 through November 16, 2020 that were paid before CMS updated the claims processing system to pay HCPCS code G2025 based on the “lesser of” methodology, as described above. (See MLN SE20016, revised  February 23, 2021).

For Medicaid, telemedicine visits (live audio and video) are considered the same as in-person visits and are paid at the same rate as regular, in-person visits.

Updated April 17, 2020

COVID-19 UPDATE: Costs for furnishing distant site telehealth services will not be used to determine the RHC AIR or the FQHC PPS rates but must be reported on the appropriate cost report form. RHCs must report both originating and distant site telehealth costs on Form CMS-222-17 on line 79 of the Worksheet A, in the section titled “Cost Other Than RHC Services.” FQHCs must report both originating and distant site telehealth costs on Form CMS-224-14, the Federally Qualified Health Center Cost Report, on line 66 of the Worksheet A, in the section titled “Other FQHC Services.”

Updated April 17,2020

COVID-19 UPDATE: For RHCs/FQHCs providing Medicare telehealth distant site services, since telehealth distant site services are not paid under the RHC AIR or the FQHC PPS, the Medicare Advantage wrap-around payment does not apply to these services. Wrap-around payment for distant site telehealth services will be adjusted by the MA plans.

Medicare Advantage (MA) plans must follow, at a minimum, the guidelines of traditional Medicare. However, individual MA plans have the flexibility to cover services beyond traditional Medicare if they choose. If the MA plans have not contacted you with any changes, we recommend that you contact them directly (and individually) to determine if they are covering more than traditional Medicare—get any guidance from them in writing.  Providers should bill the same as traditional Medicare unless otherwise instructed by the MA plan.

The Medicaid Managed Care (MCO) plans have been instructed to follow the same billing procedures as traditional Medicaid and reimburse, at a minimum for the same services and at the same rate as traditional Medicaid. However, MCOs have the flexibility to cover additional services beyond traditional Medicaid. We recommend that you contact your MCOs directly (and individually) to determine if they are covering more than traditional Medicaid—get any guidance from them in writing.

Updated March 31, 2020

COVID-19 UPDATE: Effective March 17, 2020, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against healthcare providers that serve patients in good faith through everyday communications technologies without a Business Associate Agreement, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency. Providers should attempt to utilize HIPAA-compliant technology to deliver telemedicine services if possible. If a HIPAA-compliant technology is not available, providers may utilize another technology but should take good faith measures to ensure the security and privacy of patient information. Public facing communications apps such as Facebook Live, Twitch, and TikTok should NOT be used.

Updated May 29, 2020

COVID-19 UPDATE: Effective March 1, 2020, during the PHE, certain Medicare telehealth services can be furnished using audio-only technology. A list of Medicare telehealth services, including indication of which services can be furnished via audio-only technology, is available at here (link updated June 19, 2020).  These services include CPT codes 99441, 99442, and 99443, which are audio-only telephone evaluation and management (E/M) services. RHCs and FQHCs can furnish and bill for these services using HCPCS code G2025. To bill for these services, at least 5 minutes of telephone E/M service by a physician or other qualified health care professional who may report E/M services must be provided to an established patient, parent, or guardian. These services cannot be billed if they originate from a related E/M service provided within the previous 7 days or lead to an E/M service or procedure within the next 24 hours or soonest available appointment.

Effective for services furnished on or after March 1, 2020 and throughout the PHE for the COVID-19 pandemic, Medicare has expanded the services that can be included in the payment for HCPCS code G0071, and updated the payment rate to reflect the addition of these services.  The temporary payment rate for HCPCS code G0071 is $24.76. The RHC and FQHC face-to-face requirements (that the patient have been seen by the provider in the last 12 months) are be waived for these services, therefore, this service may be furnished to new patients.

The following services are included under G0071:

• HCPCS code G2012: Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.
• HCPCS code G2010: Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment.
• 99421: Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes (VIA PATIENT PORTAL)
• 99422: Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 11-20 minutes (VIA PATIENT PORTAL)
• 99423: Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 21 or more minutes (VIA PATIENT PORTAL)

When billing Medicaid, for the duration of the COVID-19 emergency (beginning with dates of service on or after March 17, 2020), in cases where an interactive audio/video system is not immediately available at the time it is needed, an interactive audio-only system (e.g., telephone) without the requirement of video may be employed, unless noted otherwise. For use of an audio-only system, the same standard of care must be met and the need and rationale for employing an audio-only system must be documented in the clinical record.

FQHCs/RHCs should bill for these services using the T1015 code on the header line, along with the applicable CPT (i.e. 99213) on the detail line, both of which should indicate Place of Service code “02” and append modifier “-95” to all lines (T1015 and all CPT codes). Payment will be made at the all-inclusive PPS rate on file for the date of service. Documentation must be made in the medical record regarding the need and rationale for employing an audio-only system.

See the most current Medicaid Provider Update on the Medicaid Updates page for more details.

Medicare reimburses RHCs and FQHCs for Virtual Communication Services (Virtual Check-Ins) under HCPCS code G0071: Payment for communication technology-based services for 5 minutes or more of a virtual (non-face-to-face) communication between an RHC or FQHC practitioner and RHC or FQHC patient, or 5 minutes or more of remote evaluation of recorded video and/or images by an RHC or FQHC practitioner, occurring in lieu of an office visit; RHC or FQHC only).  The bill this code, the patient must have had a billable visit within the previous year and the medical discussion or remote evaluation is for a condition not related to an RHC or FQHC service provided within the previous 7 days, and does not lead to an RHC or FQHC visit within the next 24 hours or at the soonest available appointment.  HCPCS code G0071 is set at the average of the national non-facility PFS payment rates for HCPCS code G2012 (communication technology-based services) and HCPCS code G2010 (remote evaluation services) and is updated annually based on the PFS national non-facility payment rate for these codes. Virtual Communication Services must be initiated by the patient. If the patient initiates a call and then requires a call back to complete the service (for example, the call is disconnected and the provider calls them back) the call is still considered to be initiated by the patient.

Note: Medicare does not consider Virtual Check-Ins a “telemedicine” visit, therefore, the Medicare telemedicine restrictions do not apply and the “02” place of service code should not be used.

Updated May 5, 2020

COVID-19 UPDATE: Effective April 30, 2020, during the PHE, CMS also allowing many behavioral health and education services to be furnished via telehealth using audio-only communications. The full list of telehealth services notes which services are eligible to be furnished via audio-only technology (and billed as a full telehealth visit), including the telephone evaluation and management visits. View the list of Medicare telehealth services here.

On an interim basis for the duration of the PHE for the COVID-19 pandemic, Medicare will reimburse separate payment for CPT codes 98966-98968 and CPT codes 99441-99443, which are normally considered non-covered services. Where code descriptors refer to “established patient,” Medicare will not conduct review to consider whether those services were furnished to established patients. CPT codes 98966-98968 may be furnished by, among others, LCSWs, clinical psychologists, and physical therapists, occupational therapists, and speech language pathologists when the visit pertains to a service that falls within the benefit category of those practitioners, and should include the corresponding GO, GP, or GN therapy modifier on claims for these services.

Medicare payment for the telephone evaluation and management visits (CPT codes 99441-99443) is equivalent to the Medicare payment for office/outpatient visits with established patients effective March 1, 2020.  When clinicians are furnishing an evaluation and management (E/M) service that would otherwise be reported as an in-person or telehealth visit, using audio-only technology, practitioners may bill using these telephone E/M codes provided that it is appropriate to furnish the service using audio-only technology and all of the required elements in the applicable telephone E/M code (99441-99443) description are met.

• 98966 (Telephone assessment and management service provided by a qualified non-physician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion)
• 98967 (Telephone assessment and management service provided by a qualified non-physician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion)
• 98968 (Telephone assessment and management service provided by a qualified non-physician health care professional to an established patient, parent, or guardian not originating from a related assessment and CMS-1744-IFC 123 management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 21-30 minutes of medical discussion)
• 99441 (Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion)
• 99442 (Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion)
• 99443 (Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 21-30 minutes of medical discussion)

During the COVID-19 Public Health Emergency, Virtual Check In codes may be utilized, if they do not result in a visit, including a telehealth visit, can be furnished to both new and established patients. Medicare has also temporarily broadened the availability of the virtual check-in codes to practitioners such as licensed clinical social workers, clinical psychologists, physical therapists, occupational therapists, and speech-language pathologists

When billing Medicaid, for the duration of the COVID-19 emergency (beginning with dates of service on or after March 17, 2020), in cases where an interactive audio/video system is not immediately available at the time it is needed, an interactive audio-only system (e.g., telephone) without the requirement of video may be employed, unless noted otherwise. For use of an audio-only system, the same standard of care must be met and the need and rationale for employing an audio-only system must be documented in the clinical record. Providers will code/bill the same as a telemedicine (audio/video) visit.  See the most current Medicaid Provider Update on the Medicaid Updates page for more details.

Medicare does not reimburse a full visit via audio-only. However, Medicare does have specific codes for “virtual check-ins”, which can be done via synchronous discussion over a telephone or exchange of information through video or image. Virtual check-ins must be initiated by the patient (the provider may educate patients that the service is available) and can only be reported for patients who have an established relationship with the provider. These codes are only reportable by the physicians and practitioners who can furnish evaluation and management (E/M) services. There is no geographic restriction on virtual check-ins. Services provided during virtual check-in cannot be related to services provided within the previous seven days or within the following twenty-four hours (or soonest available appointment). Virtual Check Ins must be initiated by the patient. If the patient initiates a call and then requires a call back to complete the service (for example, the call is disconnected and the provider calls them back) the call is still considered to be initiated by the patient.

Virtual check-ins are billed as follows:

• HCPCS code G2012: Brief communication technology-based service , e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.
• HCPCS code G2010: Remote evaluation of recorded video and/or images submitted by an established patient(e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment.

Note: Medicare does not consider Virtual Check-Ins a “telemedicine” visit, therefore, the Medicare telemedicine restrictions do not apply and the “02” place of service code should not be used.

Updated March 31, 2020

COVID-19 UPDATE: During the COVID-19 Public Health Emergency, Medicare will not conduct review to consider whether these services were furnished to established patients. Medicare is also temporarily designating HCPCS codes G2061-G2062 as communication technology-based services (CTBS) “sometimes therapy” services that would require the private practice occupational therapist, physical therapist, and speech-language pathologist to include the corresponding GO, GP, or GN therapy modifier on claims for these services. CTBS therapy services include those furnished to a new or established patients that the occupational therapist, physical therapist, and speech language pathologist practitioner is currently treating under a plan of care.

Medicare defines an e-visit as a non-face-to-face patient-initiated communication with their doctor via the online patient portal. E-visits can only be reported when the billing practice has an established relationship with the patient and communication must be initiated by the patient. However, the provider can educate the patient that the service is available. There are no geographic or location restrictions for these visits. The services may be billed using CPT codes 99421-99423 and HCPCS codes G2061-G2062, as applicable. The Medicare coinsurance and deductible would generally apply to these services.

Note: Medicare does not consider e-visits “telemedicine” visits, therefore, the Medicare telemedicine restrictions do not apply and the “02” place of service code should not be used.

Updated April 8, 2020

COVID-19 UPDATE: During the PHE for the COVID-19 pandemic consent for Medicare virtual check-ins and e-visits can obtained when the services are furnished instead of prior to the service being furnished, but must be obtained before the services are billed. To enhance beneficiary protection, for both new and established patients, Medicare suggests that the physician or other health care practitioner review consent information with a beneficiary, obtain the beneficiary’s verbal consent, and document in the medical record that consent was obtained.

Medicare requires an annual consent for virtual check-ins and e-visits prior to a visit taking place.  This consent may be obtained by auxiliary staff under general supervision, as well as by the billing practitioner.

For services provided via telemedicine, Louisiana Law (LA Admin. Code 46:XLV.7511) requires that “in addition to any informed consent and right to privacy and confidentiality that may be required by state or federal law or regulation, a physician shall insure that each patient to whom he or she provides medical services by telemedicine is:

1. Informed of the relationship between the physician and patient and the respective role of any other health care provider with respect to management of the patient; and
2. Notified that he or she may decline to receive medical services by telemedicine and may withdraw from such care at any time.”

Consent information should include the risks of telemedicine, including delays, equipment failures, and security breaches. Patients should also be provided sufficient information to adequately address and explain the limitations of computer technology. Consent should be written with signature and conducted via oral acknowledgment and noted in the patient’s medical record for the telemedicine visit.

Sample consent forms:

• Sample Telemedicine Consent Form
• Sample Teletherapy Consent Form

Updated April 14, 2020

COVID-19 UPDATE: CMS provided in the March 2020 COVID-19 & HIPAA Bulletin: Limited Waiver of HIPAA Sanctions and Penalties During a Nationwide Public Health Emergency, a list and discussion of all waived HIPAA requirements during COVID-19.  Any HIPAA requirements NOT identified in this bulletin are not waived and, therefore, must comply with normal HIPAA guidelines. Release of Information requirements are not waived in this bulletin. HHS has also provided a decision making algorithm to help determine proper disclosure of protected health information for during a public health emergency.

A patient must sign an Authorization for Release of Information before their medical record documentation can be released to their PCP. This requirement also applies to services delivered via means of telemedicine.

There are several options to obtain a completed, signed, HIPAA-compliant Authorization for Release of Information. Below are some examples:

• If your EHR system has a Patient Portal, invite the patient to request and/or download the record(s) directly through the portal.  From there, they can provide them to their PCP.
• Email a blank Authorization for Release of Information form to the patient and invite them to complete it, sign it, and return to you via:
  • Email: The completed document should be password protected or returned via a secure email server in order for the transaction to remain HIPAA-compliant.
  • Fax: The completed document returned via fax constitutes a compliant HIPAA transaction.
  • Mail: The completed document returned via mail constitutes a compliant HIPAA transaction.
• Mail a paper Release of Information form to the patient and ask them to complete, sign it, and return it to you via mail or fax. The patient may request you mail the records back to them, or directly to their PCP.

Updated March 31, 2020

The TexLa Telehealth Resource Center is a federally-funded program designed to provide technical assistance (guidance) and resources (at no cost) to new and existing telehealth programs in Texas and Louisiana. TexLa TRC is part of the National Consortium of Telehealth Resource Centers that share knowledge and resources across the U.S. The Northeast Telehealth Resource Center developed a Telehealth Resource Webliography for COVID-19 Pandemic that contains an extensive list of valuable resources.

Questions can be submitted via the TexLa website, emailed to texlatrc@ttuhsc.edu, or called in to 806-743-7960 or toll-free 877-391-0487. You can also submit questions in the form below.

Updated May 15, 2020

This funding does not prevent other federal or state funding however (it cannot duplicate it).  This funding is to cover losses related to the COVID-19 pandemic. However, we are waiting further guidance on funding categories and what it can cover.

Updated May 29, 2020

Yes. During the COVID-19 PHE, CMS is not enforcing or conducting audit to ensure a prior relationship existed for any telemedicine services for Medicare claims submitted during this public health emergency. Louisiana Medicaid does not limit telemedicine services to established patients.

Updated March 23, 2020

Yes, the CDC now has published new guidance meant to help facilities optimize the use of eye protection, isolation gowns, face masks and N95 respirators.

 LDH has also released the “Personal Protective Equipment (PPE) Recommendations and Guidance for PPE extension during crisis for Healthcare Personnel” which can be found on the LDH website.

Updated March 21, 2020

Considerations can be made to use N95 respirators beyond the manufacturer-designated shelf life for care of patients with COVID-19, tuberculosis, measles, and varicella.

https://www.cdc.gov/niosh/npptl/respirators/testing/ExpiredN95results.html

Updated March 23, 2020

All facilities should first rely on their normal vendors. Vendors are restocking daily as this situation evolves. If your vendor still cannot fill your order, the LDH Emergency Operations Center has a PPE Planning Cell that is working hard to maintain a list of vendors who do have PPE available for purchase.

You can call the State Supply Hotline at 225-325-5900 to be put on their list as supplies become available. This phone line is available seven days a week from 8:00 a.m. to 5:00 p.m. CST. This is not a guarantee that you will receive PPE–LDH is prioritizing supplies based on need. You may receive some of your request in an effort to assist as best they can. They understand there are shortages of supplies across the state and the U.S., so please be patient.

Updated March 23, 2020

We understand that there has been significant requests for PPE and other medical supplies/equipment. Previously you may have been told to go through your Parish EOP (Emergency Operations Center) or use the app, ReadyOps–effectively immediately, please discontinue using those avenues.

LDH has provided PPE and other medical supplies/equipment page on their website. On this webpage, there is a downloadable list of vendors you can contact to place an order. These vendors have let LDH know that they do have PPE available for purchase.

Well-Ahead Louisiana maintains a comprehensive database for all RHCs. This database contains the contact information of the facility administrator and the staff person assigned to conduct emergency preparedness activities. Contact Denise Dowell (denise.dowell@la.gov) to ensure your facility’s contact information is up-to-date.

All HAN messages are posed on the LDH website at http://ldh.la.gov/index.cfm/page/3865

Updated March 25, 2020

On March 13, 2020, HHS Secretary Azar declared public health emergency and authorized waivers and modifications under Section 1135 of the Social Security Act, retroactive to March 1, 2020. The 1135 waivers typically end no later than the termination of the emergency period.

Updated March 25, 2020

You do NOT need to apply for an individual waiver if a blanket waiver is issued. On

March 16, 2020, CMS announced blanket waivers of certain Medicare requirements to prevent gaps in care for beneficiaries. The 1135 waiver authority applies only to Federal requirements and does not apply to State requirements for licensure and conditions of participation.

Updated March 25, 2020

Temporarily waive requirements that out-of-state providers be licensed in the state where they are providing services when they are licensed in another state.

This applies to Medicare and Medicaid.

Establish a toll free hotline for non-certified Part B suppliers, physician practitioners to enroll and receive temporary Medicare billing privileges.

Waived the following screening requirements:

• Application Fee
• Criminal Background checks associated with FCBC
• Site visits
• Postpone all revalidation actions
• Allow licensed providers to render services outside of their state of enrollment
• Expedite any pending or new applications from providers

Updated March 25, 2020

CMS is waiving requirements to allow acute care hospitals to house acute care inpatients in excluded part units where the beds are appropriate for acute inpatient care.

• The PPS hospital should bill for the care and annotate the patients’ medical record to indicate this is an acute care inpatient being housed in the excluded unit because of capacity issues related to the emergency.
• This includes distinct part inpatient psychiatric units, that as a result of the emergency, need to relocate inpatients from the excluded distinct part psychiatric unit to an acute care bed and unit.
• The hospital should continue to bill for inpatient psychiatric services and annotate the medical record to indicate the patient is a psychiatric inpatient being cared for in an acute care bed because of capacity issues related to the emergency.
• This also applies to Excluded Inpatient Rehab Unit and Long Term Care Acute Hospitals LTCHs Unit.

Updated March 25, 2020

CMS is waiving the requirements that CAHs limit the number of beds to 25, and the length of stay be limited to 96 hours.

This will allow urban hospitals to send patients back to their communities and give the urban hospitals more capacity.

Updated March 25, 2020

Waiving of the 3 midnight rule for coverage in the skilled nursing facility stay provides temporary emergency coverage of SNF services without the qualifying hospital stay who need to be transferred as a result of the emergency.

For certain beneficiaries who recently exhausted their SNF benefits, it authorizes renewed SNF coverage without first having to start a new benefit period.

Updated March 25, 2020

CMS directs all swing bed and nursing home providers to significantly restrict visitors and nonessential personnel, as well as restrict communal activities inside facilities. These new measures supersede prior CMS guidance. For each person gaining entrance into the facility a record should be maintained documenting assessment of symptoms and fever.

These new measures supersede prior CMS guidance and include:

• Restricting all visitors, effective immediately, with exceptions for compassionate care, such as end-of-life situations. In these situations, visitors will be screened for fever and respiratory symptoms and equipped with PPE. The visit will be limited to a specific room only.
• Restricting all volunteers and non-essential health care personnel and other personnel (i.e. barbers).
• Canceling all group activities and communal dining.
• Implementing active screening of residents and health care personnel for fever and respiratory symptoms.

Updated March 25, 2020

In an effort to keep beneficiaries safe from the virus and to remain sheltered in their residence Medicare is paying for office, hospital, and other visits furnished via telehealth including patient’s place of residence starting March 6, 2020.

These visits can be a range of providers such as doctors, NPs, clinical psychologists, and LCSWs and will be able to offer telehealth to their patients. For CMS descriptions of visits and CPT/HCPCS codes, visit https://www.cms.gov/files/document/se20011.pdf

Updated March 24, 2020

OPH and OSFM inspections have been suspended. These need to be completed as soon as their services resume. License renewals will not be delayed—renewals will be issued without inspections. Please note that payment no longer goes to New Orleans, but to Dallas.

Updated March 31, 2020

A letter released from the White House Coronavirus Task Force on March 29, 2020 includes information on reporting in-hospital laboratory testing for COVID-19. View the letter here.

Hospitals are also being asked to report on COVID-19 patients being treated in their hospitals through the National Health Safety Network. For guidelines on the Patient Impact and Hospital Capacity Module, click here.

Updated October 8, 2020

On March 30, 2020, CMS announced expansion of its accelerated and advance payment program for Medicare participating health care providers and suppliers. To qualify for accelerated or advance payments, the provider or supplier must:

• Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s/supplier’s request form,
• Not be in bankruptcy,
• Not be under active medical review or program integrity investigation, and
• Not have any outstanding delinquent Medicare overpayments.

Medicare will start accepting and processing the Accelerated/Advance Payment Requests immediately and anticipates that the payments will be issued within seven days of the provider’s request.

An informational fact sheet on the accelerated/advance payment process and how to submit a request has been released and can be viewed here.

Updated March 31, 2020

Read the full press release here.

Updated March 30, 2020

Read the full bulletin here.

The CARES Act is short for the Coronavirus Aid, Relief and Economic Security Act passed by Congress in response to the coronavirus emergency. The CARES Act includes funding for individuals, families, business, and healthcare providers and is sometimes also referred to as the “stimulus bill.” The CARES Act can be read here.

CMS has clarified that the 3-day prior hospitalization waiver applies to swing bed stays between a critical access hospital (CAH) and other acute care hospitals (as well as for patient transfer within a hospital). This waiver is effective from March 1, 2020 until the declared end of the current Public Health Emergency (PHE). The patient must still have at least one reasonable and necessary daily qualifying skilled need, and the CAH must still be Swing Bed certified at this time. To read the full response from CMS, click here.

For information on how this rule change also benefits large hospitals that may be discharging patients to CAHs, click here.

Updated June 9, 2020

The Centers for Medicare & Medicaid Services (CMS) released a fact sheet on State and Local Governments CMS Programs & Payment for Care in Hospital Alternate Care Sites.

Updated March 21, 2020

The OPH/Epidemiology line for medical providers (available 24/7) is 1-800-256-2748.

Updated March 21, 2020

Louisiana COVID-19 General Information line (available 8 a.m.-4:30 p.m.) is 1-855-523-2652.

Updated March 23, 2020

Global surveillance data is kept by the World Health Organization.

Updated March 18, 2020

Learn how to stop the spread with this Louisiana Department of Health guide.

Updated March 23, 2020

Please join the Provider Education Network by visiting this webpage.

By signing up, you will receive bi-monthly communications that will include COVID-19 updates, as well as information, education, and resources that touch on a variety of topics, including quality measures, related chronic disease, community engagement, health innovation, and changes and updates in regulations/legislation affecting our care.

You will also be added to our Provider Education Network Alerts which include time sensitive information that can relate to COVID-19 updates.

EOC: Emergency Operations Center

PPE: Personal Protective Equipment

AAR: After Action Report

SNS: Strategic National Stockpile

MMS: Medical Monitoring Station

MLN: Medicare Learning Network

If you have questions about additional acronyms, please submit them in the form at the bottom of this webpage, and they will be added to this list.

Updated April 23, 2020

The National Association of Rural Health Clinics released a publication regarding relief for loss of revenue during this pandemic. To read the full publication, click here. More information on the relief fund will be provided when details become available.

Updated June 19, 2020

Each organization will need to complete the attestation process to accept or reject the Rural Health Clinic Testing funds within 45 days of receipt of payment via ACH or within 60 days of check payment issuance. Not returning the payment or attesting to the receipt of funds within this timeframe will be viewed as acceptance of the terms and conditions, view the guidance here.

Updated May 20, 2020  

The CDC has provided specific guidance regarding workers being exposed to COVID-19 which states the Interim U.S. Guidance for Risk Assessment and Public Health Management of Healthcare Personnel with Potential Exposure in a Healthcare Setting to Patients with Coronavirus Disease 2019 (COVID-19). See below links:

• Interim U.S. Guidance
• Dos and Don’ts

Updated May 15, 2020

This funding does not prevent other federal or state funding however (it cannot duplicate it).  This funding is to cover losses related to the COVID-19 pandemic. However, we are waiting further guidance on funding categories and what it can cover.

Updated July 8, 2020

Many RHCs have had to change the way they staff their clinics and bill for RHC services during the COVID19 public health emergency (PHE). As a result, these RHCs may have difficulty in meeting the productivity standards. To minimize the burden on RHCs, exceptions to the productivity standard may be granted by your MAC during the COVID-19 PHE. Further direction will be forthcoming from your MAC. Please see MLN Matters Article SE20016 for more information.