HealthEfficient Telehealth Q&A
This information is prepared for informational purposes only, and should not be considered legal advice. For more complete and up-to-date advice, please consult with your attorney and/or Primary Care Association.
Information is up to date as of March 22, 2020.
General Telehealth Questions
Question: Should consent for telehealth visits be written or verbal?
Answer: Per CMS, verbal patient consent must be obtained and documented in the note/medical record of each virtual or telehealth encounter. This does not necessarily mean you need the patient’s written consent; just that consent should be documented. Some telehealth platforms enable written consent processes prior to the visit starting.
Question: How should patient consent be documented?
Answer: The patient’s verbal consent must be documented in the note/medical record associated to each virtual or telehealth encounter.
Question: Do I need to document the patient’s consent once or on each encounter?
Answer: The patient’s verbal consent must be obtained and documented on each virtual or telehealth encounter in the progress note/medical record.
Question: Is there any guidance on telehealth documentation requirements?
Answer: Progress notes/records should be documented the same way as an in-person visit. Per MGMA, the information of the visit, the history, review of systems, consultative notes or any information used to make a medical decision about the patient should be documented. Best practice suggests that documentation should also include a statement that the service was provided through telehealth, both the location of the patient and the provider and the names and roles of any other persons participating in the telehealth service.
Question: Is Medicare allowing FQHCs to be distant site providers?
Answer: Not currently. Per Medicare, FQHCs and RHCs may act as originating sites but not as distant site providers.
Question: Is it true that even with the recent Medicare changes to telehealth that an FQHC provider must be on-site and they cannot be at home providing the service?
Answer: Correct, the location of the provider is considered the distant site and there have been no federal restrictions or limitations waived on distant sites at this time. However, some states may allow the provider to provide Telehealth services from their home to Medicaid beneficiaries.
Question: Medicare lifted the originating site requirement, but I can’t find anything clarifying how New York Medicaid will handle telehealth visits where the provider and/or patient are home, the 994xx codes are specific to phone or web portal medical discussions.
Answer: For clarification, Medicare has lifted geographic limitations on originating sites (where the patient is located). Meaning, the Metropolitan Statistical Area (MSA) or rural Health Professional Shortage (HPSA) restrictions do not apply and the patient’s home is considered an acceptibleoriginating site under the 1135 waiver. NY Medicaid considers any secure location within the United States to be an eligible distant site, including the provider’s home (this was made more explicit in late March 2020). The patient’s home may be an originating site. Please also note that Telehealth and Telephone encounters are not the same. Telehealth encounters are typically coded as an in-person encounter would be, whereas CPTs 99441, 99442 and 99443 are for visits conducted over the phone or via web portal.
Question: What licensure do our providers need?
Answer: Licensure requirements vary by state. Please consult with your state’s telehealth policy or PCA. Per Medicare, FQHCs may act as an originating site, which would include the typical “core providers”:
· Physicians
· Physician Assistance (PAs)
· Nurse Practitioners (NPs)
· Nurse Midwives
· Clinical Psychologists (CPs) and Clinical Social Workers (CSWs)
Question: Are FQHCs exempt from relaxed HIPAA regulations?
Answer: The federal waiver regarding potential penalties associated with providing telehealth services via non-HIPAA compliant platforms should not be taken advantage of at this time. HealthEfficient strongly believes it is better to err on the side of caution and use a HIPAA compliant platform and prodedures as there are several to choose from and it will lead to less complications post-epidemic.
Question: Will coding specifics for Washington, DC be provided?
Answer: HealthEfficient will be providing state- and jurisdiction specific guidance as soon as possible. Please check with DCPCA for the latest billing and remibursement regulations there. In all cases, HealthEfficient defers to the PCA to provide the latest regulations, as this task is morely in the scope of the PCA program than the HCCN program. (HealthEfficient is an HCCN.)
Question: Can you provide telehealth information for Maryland?
Answer: HealthEfficient has provided written guidance for telehealth billing in Maryland. Please check with MACHC for the latest information on billing regulations.
Question: For telehealth visits that must be initiated by the patient, how does that impact mental health patients who are seen weekly? Does this mean they have to ask for another follow-up session and the therapist should not ask?
Answer: Initiation refers to the need of an appointment. If the patient would have normally scheduled a recurring/weekly appointment, a provider may offer to render these services virtually instead of in-person. This criterion was put into place to prevent health care professionals from lobbying patients for unnecessary services.
Question: Does the GT modifier need to be attached on each claim?
Answer: This will vary by state. HealthEfficient will be providing state-specific guidance as soon as possible. You may also check with your PCA on billing regulations. Medicare requires GT modifier on all distant site claims but FQHCs are not eligible distant site providers and therefore the modifier is not applicable.
Question: If we are calling the patient and using the G2012 for virtual check-in, is this going to Part B?
Answer: This is still being researched as no conclusive answer has been found at this time. It has been confirmed that the virtual check-ins are not eligible for the Prospective Payment System (PPS) rate and will be reimbursed according to the Physician Fee Schedule (PFS). It has also been published that G0071 should be used in lieu of G2012, G2010. Additional information will be provided as soon as possible.
Question: Are Telehealth visits billed to Medicare Part A or Part B?
Answer: FQHCs should bill telehealth encounters to Medicare Part A on a facility/UB claim type. FQHC originating sites should apply HCPCS code Q3014 with revenue code 0780 to receive an originating site facility fee.
Question: How will we know if an FQHC has opted in to an APG?
Answer: The mention of APGs (Ambulatory Patient Groups) during the webinar was specific to New York FQHCs. Opting into an APG would require forms to be completed. You may confirm whether your organization has opted into an APG reimbursement with your credentialing or contracting director.
Question: Can we reschedule visits to telehealth if they are already on the schedule as face-to-face visits?
Answer: Yes, if the patients are already on your schedule for an in-person visit, you may contact them and offer a virtual or telehealth encounter instead.
Question: Can we have the visit (CPT) codes for behavioral health?
Answer: Please refer to the Covered Telehealth Services CY 2019 and CY 2020 published by CMS. Telehealth eligible services may also vary by state. Please check with your PCA for state-specific guidance.
Question: Can we have the “at home” guidelines for New Jersey?
Answer: HealthEfficient will be providing state-specific guidance as soon as possible. You may also check with NJPCA on billing regulations.
Question: What are the guidelines for patient cost-sharing?
Answer: Federally, cost-sharing amounts related to COVID-19 testing and treatment are waived. Cost-sharing for services rendered during the public health emergency that are not related to the testing and treatment of COVID-19 still apply but the OIG is providing flexibility to providers who choose to reduce or waive these out-of-pocket expenses.
Question: What are telehealth users using for interpreters?
Answer: Hospitalists normally use a phone translation service where they call a number, get an interpreter, put the phone on speaker and the interpreter can help with two-way translations
eClinicalWorks/healow/TeleVisits Q&A
Question: Are eCW users experiencing barriers linking patients to patient portal to use TeleVisits?
Answer: As long as the patient is web-enabled, they are linked and have access to the patient portal and will be able to use TeleVisits
Question: Do patients have to be linked to the portal for TeleVisits?
Answer: Yes, patients need to be web-enabled to be able to utilize eCW TeleVisits
Question: Are there concerns about the data requirements for these apps? Does Zoom app user more/less than healow? Our patients have limited data and may be hesitant to use the app.
Answer: Not sure about other apps, but eCW network requirements are fairly low and the video quality is updated based on the available bandwidth, and can even switch to just audio
Question: For the patient to show as arrived at the health center, do we need just need to synchronize the visit type code to the portal?
Answer: No, the appointment visit code will update automatically once the patient has arrived on the TeleVisit and initiated the visits
Question: If the visit is initiated by intake staff (medical assistant, for example), can a provider enter after alerted by the MA?
Answer: Only a registered TeleVisit provider can initiate (click Start Visit from the progress note) a TeleVisit
Question: What time are the daily eCW Telehealth webinars?
Answer: The webinar schedules are published on the eCW Customer Portal (https://my.eclinicalworks.com)
Question: I am a dietician/CDE and listed as a resource in eCW, can I use TeleVisits?
Answer: No, you need to have an active eCW license, NPI and email address to utilize TeleVisits in eCW.
Question: Can providers without an NPI, such as nurses and medical assistants access eCW TeleVisits?
Answer: No, not currently. For a provider to utilize TeleVisits in eCW they must have an active eCW license, NPI and email address.
Question: What is the best way to obtain and capture consent using eClinicalWorks healow?
Answer: Questionnaires can be customized by the health center to include a consent question; in which case the questionnaire must be imported into the progress note. Otherwise, consent should be requested and obtained verbally and documented in the progress note.
Question: Can eCW resources use TeleVisits or just providers?
Answer: Only providers with an active eCW license, NPI and email address can register for and use TeleVisits in eCW.
Question: Can patients access a telehealth visit through their smartphone?
Answer: Yes, however, patients will need to have the healow app installed on their smartphone to access the TeleVisit.
Question: What is the cost associated to using eCW TeleVisits?
Answer: eCW currently offers two pricing options for TeleVisits: 1. $2 per visit -OR- 2. $50 for 250 minutes, billed monthly and minutes do not roll-over.
Question: Do you have to have a camera for eCW TeleVisits, so desktops won’t work unless you have an external camera?
Answer: Yes, you will need to have a camera for two-way visual interactions with the patient. This is a telehealth requirement, not limited to eCW.
Question: Is the eCW healow platform available in Spanish?
Answer: No, not currently.
Question: Is the Patient Portal available in languages other than English?
Answer: No, not currently.
Question: Will the training video be available later?
Answer: eCW hosts daily webinars regarding telehealth. Schedule and recorded webinars are available on the customer support portal https://my.eclinicalworks.com. HealthEfficient has recorded this entire webinar and shared the link with participants on Friday, 3/20/2020.
Question: If the visit is initiated by intake staff (medical assistant, for example), can a provider enter after alerted by the MA?
Answer: Only the registered provider can initiate the visit (click Start Visit in the TeleVisit Progress Note).
Question: Can appointment links be sent via text for those without email addresses?
Answer: TeleVisit appointment reminders may be sent via voice call, text or email. However, links to the appointment are only available via email or through logging into the Patient Portal or healow app directly. Also, TeleVisits are only accessible for web-enabled patients, which requires a valid email address.
Question: Is there a plan to have authorized interpreters within healow join the TeleVisit encounter for a 3-way conversation with the patient?
Answer: No, not currently. eClinicalWorks advised they will consider this in future enhancement opportunities.
Question: Is the patient questionnaire the same setup as other questionnaires in the EXE version for the portal? If we want to add a consent question, we will need to build a statement in our eCW categories?
Answer: Per eClinicalWorks, yes, the patient questionnaire setup is the same as how it is currently being done in EXE or WEB. At this point of time, if a practice wants patient consent for televisits, they will need to create a support case and provide the support team with the consent template, which will be published by the support team. We are currently in the process of releasing a server-side patch in the next few weeks, which has the enhancement for practice administrators to control the TeleVisit patient consent. eCW will be pushing this update to all eCW-hosted customers in the next week, and once the patch has been enabled for self-hosted practices, the SAM will notify the practices to run the APU tool to get this update.
Question: Can a user create questionnaires by visit type or age?
Answer: Questionnaire templates can be built and published on the Patient Portal and for TeleVisits based on Provider, Facility and Visit Types but not patient age.
Question: Is there any plan to add the ability for the Nurse to be able to use TeleVisits to keep care plan follow-up?
Answer: No, not currently.
Question: What is the status of doing eCW TeleVisit group visits?
Answer: This is not an option at this time. eClinicalWorks advised they will consider this in future enhancement opportunities.
Additional information:
Questions were answered from a federal perspective, unless otherwise specified, based on information available at the time of publishing. For state-specific guidance, you may reach out to your PCA for the most up to date information and guidance. State telehealth policies are also available on the CCHPCA’s interactive web page: CCHPCA Current State Laws and Policies Interactive Map