Home Health & Hospice Week

Manual coding could introduce errors.

The new requirement to report home health telehealth services and telemonitoring hits in just a couple of weeks, but it may not be easy.

Background: In its 2023 home health final rule issued last fall, the Centers for Medicare & Medicaid Services finalized a proposal for home health agencies to use three new G codes to report telehealth services — G0320, G0321, and G0322 (see box, p. 172). HHAs were cleared to start “voluntary reporting of the new G-codes beginning with HH periods of care that start on or after January 1, 2023,” according to the transmittal implementing the change. Then HHAs must begin “mandatory reporting beginning with HH periods of care that start on or after July 1, 2023,” indicated CR 12805 (see HHHW by AAPC, Vol. XXXI, No. 39-40).

Theoretically, HHAs have had nearly six months to get used to the requirement. “Agencies have been able to practice and organize themselves around reporting these since January,” points out Linda Scott with Scott Solutions in Arlington, Virginia. And “G codes as a concept aren’t new,” Scott tells AAPC.

But in reality, challenges abound, experts agree.

The most impactful ones may be financial. “Since the telemonitoring reporting does not affect reimbursement, it is simply not on the radar” of many HHAs, believes consultant Pam Warmack with Clinic Connections in Ruston, Louisiana. “In my experience, home health providers do not pay a great deal of attention to anything that does not affect reimbursement,” Warmack notes.

In addition to no direct payment, “there aren’t penalties for not doing it,” Scott highlights. Plus, “there is no promise that any data will generate additional reimbursement,” she adds.

Another challenge is more conceptual. “The first COVID-19 Public Health Emergency (PHE) interim final rule with comment period … changed the plan of care requirements at Subsection (§) 409.43(a) … to state that the plan of care must include any provision of remote patient monitoring or other services furnished via a telecommunications system. The plan of care must also describe how the use of such technology is tied to the patient-specific needs as identified in the comprehensive assessment and will help to achieve the goals outlined on the plan of care,” CR 12805 recounts. “The CY 2021 HH PPS final rule with comment period (85 FR 70298) finalized these changes on a permanent basis,” it adds.

In other words, “telehealth services are supposed to be on the plan of care,” Scott emphasizes.

“Management personnel in the provider community have difficulty envisioning how to implement the telehealth piece as part of the plan of care,” Warmack finds. “It must be part of the patient’s unique plan of care and documentation in the record must show how it works towards achieving the goals for the patient,” she stresses. “That can be a nebulous concept for some,” she tells AAPC.

Even when agencies can figure out how to integrate telehealth services and telemonitoring into the POC, syncing that up with billing is the next hurdle.

“The largest challenge I anticipate for agencies might be the capture of service in the [electronic medical record] to be coded for billing,” Scott expects. “What’s on the plan of care should be accounted for in the EMR for clinical record and billing. And, the EMR generates bills,” she explains.

“It is very probable that the EMR and the telehealth system are not integrated,” Scott elaborates. “So the agency has to create a way for those three different types of telehealth encounters to be coded to the patient’s record — manually.”

And of course, manual coding is “error prone,” Scott cautions.

It’s also not great that the switch to mandatory reporting is coming on July 1. “The summer months are particularly difficult for home health providers,” Warmack observes.

And agencies have so much on their plates already, Warmack says. “The workforce crisis is still very real,” she stresses. “The shortage of clinicians continues and providers are continuing to deal with that problem.”

On the other hand, “of course, telehealth through remote monitoring and telecommunications can be used to alleviate some of that burden,” Warmack reminds.

Seize This Opportunity

Another plus is that thanks to the voluntary reporting window that started in January, “several CMS/MAC processing clarifications/corrections have been made,” notes Elizabeth Wilson with FORVIS in Springfield, Missouri. That “will hopefully make the upcoming requirement and claims processing run smoothly,” Wilson tells AAPC. (For more details on the corrections, see Home Health & Hospice Week by AAPC, Vol. XXXII, No. 7.)

“Many agencies already had a telehealth program in place or rolled one out during the pandemic,” Scott observes.

But whether you’re looking to put a whole program into place or just figure out how to report what you’re already doing, you should view the new requirement as an “an opportunity,” Wilson suggests. “Collecting data now for analysis [can lead] to possible improvements in the future,” she says.

Keep your eye on the overall benefit of telehealth. It can “help expand access, engagement and patient monitoring in an effort to improve quality, reduce rehospitalization, and try to reduce costs by reducing in-person visits,” Scott emphasizes.

Note: The 20-page CR is at www.cms.gov/files/document/ r11502cp.pdf.