Understand Virtual Services Billable During the COVID-19 Public Health Emergency

When considering providing virtual services during the PHE, hospitals should carefully consider new reimbursement mechanisms to ensure compliance.

This article appears in the May/June 2020 edition of HealthLeaders magazine.

In response to the COVID-19 pandemic, Congress and CMS have made it easier to provide a variety of services to patients remotely or through technology (i.e., virtual services) for the duration of the public health emergency (PHE) declaration.

CMS recognizes three types of billable virtual services: telehealth, virtual check-ins, and e-visits. For the duration of the PHE, two additional categories may be covered under specified circumstances: telephone evaluation and management (E/M) services; and hospital outpatient therapy, education, and training services.

Telehealth is provided through audiovisual technology and billed with regular codes for face-to-face services, when provided by eligible providers under approved circumstances. Virtual check-ins and e-visits have defined codes that specify they are not face-to-face services.

Telehealth is normally limited to rural or health professional shortage area (HPSA) facility originating sites (the site where the patient is located). During the PHE, the originating site can be anywhere, including the patient's home. CMS has provided flexibility to temporarily "relocate" a portion of a hospital's current provider-based department (PBD) to a patient's home. This allows the hospital to bill an originating site fee when providing support for telehealth services to the patient.

The physician (the distant site provider) bills a telehealth-approved face-to-face code. CMS has added 85 codes for use during the PHE, including emergency department and initial inpatient and observation services.

Virtual check-ins are brief communications through synchronous or asynchronous technology, which do not result from or result in a visit with the provider.

E-visits are patient-initiated evaluation and management services through a patient portal. Unlike telehealth, e-visits may be provided by a wider range of practitioners, including physical and occupational therapists. 

During the PHE only, CMS has established coverage and payment under the Physician Fee Schedule for telephone E/M services.

Also during the PHE, CMS is allowing hospitals to bill a specified list of behavioral health, physical and occupational therapy, education, and training services delivered by telecommunication technology. Hospitals may bill and be paid for these services when provided by hospital staff to a patient registered as a hospital outpatient and located in a PBD, including the patient's home if it has been designated a relocated PBD by the hospital.

When considering providing virtual services during the PHE, hospitals should carefully consider new reimbursement mechanisms to ensure compliance. CMS is allowing payment of some virtual services to hospitals if they relocate their PBDs to expansion locations, including patients' homes. However, there are steps hospitals must take to be compliant, including notifying CMS of the relocated addresses, and ensuring the locations meet Conditions of Participation not waived through CMS' Hospitals Without Walls initiative. Nevertheless, these new mechanisms for reimbursement represent much-needed economic relief for hospital outpatient departments.