CMS recently released an updated IFR advancing and relaxing regulations regarding telehealth for healthcare providers. What this means for wound care providers is that telehealth is now a viable option that gives you a way to continue providing high quality care for your Medicare beneficiaries within the walls of an outpatient wound care department or when you visit the patient within a skilled nursing facility.
Under the new regulations as of this writing, here are five benefits for wound care providers:
- Medicare beneficiaries can now receive three types of virtual services: telehealth, virtual check-ins and e-visits (1), which means that physicians can maintain continuity of care and patient engagement for patients with wounds. Conditions for the provision of these services is methodically outlined in the regulations.
- Requirements for documentation of history and/or the physician exam in the medical record during the office/outpatient E/M have been relaxed, stating “we are clarifying that the office/outpatient E/M level selection for services under the primary care exception when furnished via telehealth can be based on MDM or time, with time defined as all of the time associated with the E/M on the day of the encounter; and the requirements regarding documentation of history and/or physical exam CMS-5531-IFC 137 in the medical record do not apply.” (2)
- Create the attestation statements needed to confirm verbal or written consent specific to participation in telemedicine, total time for the virtual visit, and identification of the secure technology used during the visit. (3)
- Use of telehealth services that expand practice access is available as an Improvement Activity under MIPS (4) giving wound care providers an option for reporting. Be sure to review the full improvement activity description to see if this measure can apply to you.
- Adding one new Improvement Activity for the CY 2020 performance period that, if selected, would provide high-weighted credit for clinicians within the MIPS Improvement Activities performance category. In order to receive credit for this activity, a MIPS-eligible clinician must participate in a clinical trial utilizing a drug or biological product to treat a patient with COVID-19 and report their findings through a clinical data repository or clinical data registry for the duration of their study. This would help contribute to a clinician’s overall MIPS final score, while providing important data to help treat patients and address the current COVID-19 pandemic. (5)
CMS has expanded the IFR to allow hospital facility charges, but there are preliminary steps that must be taken first. CMS outlines the process in their Hospitals waiver document and in the interim final rule. Please check with your hospital billing department and carrier policies for clarification and potential updates. Hospitals that employ QHP within the wound care departments and provide professional billing would maintain their same billing practices.
It is important to understand how to align the regulations providing these benefits for your place of service. Ensure you are armed with the tools necessary to provide patient engagement and continuity of care, including your Patient Portal and HIPAA-compliant videoconferencing connection. To quote CMS within the IFR, “As always, documentation in the medical record of the reason and necessity of the visit is required.”
Net Health is now offering a telehealth option with our WoundExpert® electronic health record (EHR) for wound care providers. See on-demand demo now.
(1, 5) Centers for Medicare & Medicaid Services. Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19. April 30, 2020. www.cms.gov/files/document/covid-19-physicians-and-practitioners.pdf. Last accessed April 30, 2020.
(2-3) Centers for Medicare & Medicaid Services. Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency. March 26, 2020. www.cms.gov/files/document/covid-medicare-and-medicaid-ifc2.pdf. Last accessed April 21, 2020. Last accessed April 30, 2020.
(4-5) Quality Payment Program. Centers for Medicare & Medicaid Services. https://qpp.cms.gov. Last accessed April 21, 2020.