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Home Health & Hospice Week

Billing:

There's No Need For All New Telehealth Codes

Published on Fri Oct 14, 2022

Audio-only encounters should still count.

If the Centers for Medicare & Medicaid Services does start gathering home health telehealth data — and hopefully reimbursing based on it — there are smart ways to do so. And its proposal isn’t one of them, commenters say.

Reminder: Medicare’s home health telehealth proposal only extends as far as three G-codes it suggests (see story, p. 286).

The National Association for Home Care & Hospice “supports collecting telecommunication services on home health claims and supports developing a mechanism to refine collecting visit details for the type of clinician and service provided,” the trade group says in its comment letter. “Capturing telecommunication visits on home health claims will greatly assist with accurate cost reporting for the use of telecommunication technologies,” it praises.

However: “There are concerns with future refinements of the G-codes that specify the type of clinician and service provided as proposed,” NAHC warns. “The creation of multiple G-codes may lead to confusion and result in inappropriate assignment of the G-codes on claims,” the letter cautions.

“CMS should be able to achieve its goal of better understanding what types of virtual services are being provided to HH patients without developing a new code set,” insists American Speech-Language-Hearing Association President Judy Rich in the trade group’s comment letter. “Having one code set to represent services provided under Part A and a separate code set for services provided under Part B would be administratively burdensome and complex,” Rich argues. “It would also prevent CMS from effectively comparing data across practice settings,” she adds.

The American Physical Therapy Association has “concerns that CMS’ exploration of this data in the home health setting, as described in the proposed rule, may be needlessly complicated, duplicative, and more burdensome on providers to learn additional coding and billing guidelines,” says APTA Home Health President Philip Goldsmith in the association’s letter.

And the National Association for the Support of Long-Term Care has “concern regarding the burden of incorporating the data collection into the workflow adding burden without acknowledgement or application of a visit or payment to offset this additional workflow,” NASL’s Cynthia K. Morton says in its letter.

“Not all home health IT systems are currently able to accommodate the automated collection and reporting of [new] codes resulting in unknown burden,” cautions Mark Besch with Aegis Therapies headquartered in Frisco, Texas. “CMS gives no indication of having studied nor estimating this burden, which we believe is critical prior to implementation,” Besch emphasizes.

Bottom line: “The creation of additional G-codes will most likely lead to mass confusion and result in inappropriate assignment of the G-codes on claims,” Texas Association for Home Care & Hospice’s Jennifer Elder warns in the trade group’s comment letter.

Many commenters agree on a method to simplify the reporting. “CMS could use a similar approach to identify telecommunication visits on home health claims as was done for physician services during the COVID-19 public health emergency,” NAHC offers. “Appending a modifier to existing G-codes on claims would be a less cumbersome approach to reporting detailed information around telecommunication visits,” it recommends.

The new G codes “would be an administrative burden to providers with staffing training and software updates,” notes Kelly MacNeill-Cooney with the National Association of Rehabilitation Providers and Agencies. “We recommend CMS utilize existing codes with the -95 modifier to track on the claims,” she urges in NARA’s letter.

In addition to using existing modifiers for billing, commenters suggest CMS:

• Avoid discipline limitations. “We ask that CMS not restrict application of G-Codes to home health aide services,” LeadingAge says. “Many states have adopted increased scopes of practices for aides that could allow use of telehealth for improved outcomes,” including assisting with medication administration and observing and reporting medication side effects, Barnett offers.

• Allow audio-only. One of the three new G-codes CMS proposes would be for audio-only interactions, but Johanna L. Beliveau, the CEO for the Visiting Nurse and Hospice for Vermont and New Hampshire, wants to make sure it stays that way. “Given the rurality of our region, robust broadband is not available in our entire patient service area,” Beliveau tells CMS. “Thus, for some patients, audio-only telehealth may be the only option of technology-based visits available.”

• Keep exemptions narrow. “CMS should, where practicable, avoid broad exemptions to ensure that as many safe and effective services as appropriate can be provided using telecommunications technologies,” Goldsmith urges.

Stay tuned: HHAs will see whether CMS heeds their feedback when it issues the final rule in late October or early November.

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