Staying abreast of the regulatory changes related to the 2019 novel coronavirus (COVID-19) and navigating its impact on your wound care practice can be a daunting task given the sheer number of announcements that have amassed. The regulatory changes during this pandemic, coupled with the need to socially distance, may provide the impetus for your implementation of telehealth. One of the first things to consider is how you triage your patients and build your workflows to accurately reflect documentation for your virtual visits. Aligning your processes and practice to incorporate the changes is the key to your clinical and operational success.
As clinicians, we like direction and process. We like algorithmic thinking that leads to interventions, such as wound-healing pathways. We are comfortable knowing that if the characteristics of the wound change, we can review the pathway for alternate care options in real time when seeing our patients. However, in light of the pandemic, what services are provided to patients, and when they are provided have changed, and telehealth has become a viable option for ensuring continuity of care for patients with wounds.
Over the last few months, telehealth regulations have been released that build upon each other and affect your site of service and your documentation. Starting on March 6, 2020, the CMS broadened access to Medicare telehealth services, allowing beneficiaries to receive a wider range of services from their providers without having to travel to a healthcare facility. On March 13, 2020, the President declared a national emergency under the National Emergencies Act and made an emergency determination under the Stafford Act. Shortly after this declaration, the CMS announced a set of waivers specific to the pandemic (COVID-19 waivers). Although each waiver is important to how we practice care, let’s review one of the waivers, Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19, issued March 30, 2020, because it affects providers in all settings during this pandemic.
This temporary regulatory waiver provides new rules to equip the American healthcare system with maximum flexibility to respond to the pandemic. A few of the areas that directly impact the wound care business include the opportunity to broaden how patients are seen via telehealth and the impact on the Merit-based Incentive Payment System (MIPS). At the time of writing, there are three main types of virtual services physicians and other professionals can provide to Medicare beneficiaries that are clearly summarized in the regulations. These visit types included Medicare telehealth visits, virtual check-ins, and e-visits. Each new service is succinctly defined including who provides the service, what codes can be used for the service, and if the service can be applied when seeing new or established patients. (For more information, review the May Practice Points column, Expanded Telehealth Services Offer Smart Wound Care Workflows.) It is important to work directly with your registration, coding, billing, and medical records departments to determine how telehealth provides you with opportunities to expand your practice and connect with your patients in a virtual setting.