Home Health & Hospice Week

RHC telehealth visits must be on the plan of care.

Hospices feeling left out of Medicare’s move to allow physician face-to-face visits via telehealth will be happy with the latest round of the program’s regulatory changes.

On March 30, the Centers for Medicare & Medicaid Services announced a raft of regulatory relief provisions for COVID-19, including allowing physicians and nurse practitioners to provide F2F for hospice recertification periods.“Given that a face-to-face visit solely for the purpose of recertifi­cation for Medicare hospice services is considered an administrative requirement related to certifying the terminal illness … we believe that such visit could be performed via telecommunications technology as a result of the [public health emergency] for the COVID-19 pandemic,” CMS says in the 221-page interim final rule containing the regulatory changes. The rule doesn’t yet have a scheduled Federal Register publication date.

The physician and NP visits won’t be separately billable, CMS points out.“Encounters solely for the purpose of recertification would not be a separately billed service, but rather considered an administrative expense,” the rule clarifies.

However: “If a hospice physician, or a hospice NP who is also the patient’s designated attending physician, provides reasonable and necessary nonadministrative patient care during the face-to-face visit, that portion of the visit would be billable under the Medicare rules,” CMS explains. In those cases, “the physician or NP may bill for such direct care services for Medicare beneficiaries under the [physician fee schedule],” the rule says.

CMS also clarifies telehealth use for hospice visits.“For the duration of the PHE for the COVID-19 pandemic, we are amending the hospice regulations … to specify that when a patient is receiving routine home care, hospices may provide services via a telecommunications system,” as long as “it is feasible and appropriate,” the rule says. That will “ensure that Medicare patients can continue receiving services that are reasonable and necessary for the palliation and management of a patients’ terminal illness and related conditions without jeopardizing the patients’ health or the health of those who are providing such services,” CMS says.

Must-do: “The use of such technology must be included on the plan of care,” CMS instructs. And “the inclusion of technology on the plan of care must ...be tied to the patient-specific needs as identified in the comprehensive assessment and the measurable outcomes that the hospice anticipates will occur as a result of implementing the plan of care.”

This is good news, says the National Hospice and Palliative Care Organization. The trade group “is encouraged by the Administration’s efforts to expand telehealth,” it says in a release about the changes.

However: “We are concerned about the inflexibility in counting of visits on the required claim forms, reporting requirements and payment,” NHPCO says.

Problem #1: “There is no payment beyond the per diem amount for the use of technology in providing services under the hospice benefit,” CMS says in the interim final rule.

Problem #2: “For the purposes of the hospice claim submission, only in-person visits (with the exception of social work telephone calls) should be reported on the claim,” the rule continues.

CMS does offer this suggestion to recognize the extra telehealth costs.“Hospices can report the costs of telecommunications technology used to furnish services under the routine home care level of care during the PHE for the COVID-19 pandemic as ‘other patient care services’ using Worksheet A, cost centerline 46, or a subscript of line 46 through 46.19, cost center code 4600 through 4619, and identifying this cost center as ‘PHE for COVID-19,’” the rule says.

Telehealth Options

Guidance on what devices and technologies providers can use to furnish telehealth visits is changing as the COVID-19 crisis develops. In a release for the interim final rule, CMS noted that “during the pandemic, individuals can use commonly available interactive apps with audio and video capabilities to visit with their clinician.”

But in a March 31 call, CMS indicated “telephone only” visits are acceptable, NHPCO reports.

Questions remain about how hospices can bill their physician services, NHPCO’s Judi Lund Person said in a March 31 webinar on hospice telehealth under COVID-19.“Attending and outside consulting physicians that bill Part B for physician visits can do so using telehealth,” Lund Person said in the presentation.

“When the same visit is done by a hospice physician and billed through Part A by the hospice … billing is not clear,” she said. The hospice claim form does not include the “Place of Service 02 code” that CMS uses and “telehealth services” aren’t generally billable by Part A providers.

Stay tuned for forthcoming clarifications.

Note: The 221-page interim final rule is at www.cms.gov/files/document/covid-final-ifc.pdf. The NHPCO slides are available via a link at www.nhpco.org/coronavirus — scroll down to the “March NHPCO Webinars on COVID-19” section.