Home Health & Hospice Week

Whether you’ve got a full blown telehealth program up and running or are just considering getting into one, now’s the time to make sure you are in compliance with Medicare’s new requirement to report home health telehealth and telemoni­toring services.

During the COVID-19 pandemic, the Centers for Medicare & Medicaid Services cleared the regulatory way for home health agencies to provide home health services and telemonitoring, and now they want HHAs to report those services on claims (see story, p. 170).

Make sure you’re in compliance with the reporting requirement taking effect on July 1 with these expert tips:

1. Know the rules. CMS spells out the requirements for agencies to report services with HCPCS codes G0320, G0321 and G0322 in July 2022 Change Request 12805. If you haven’t already done so, “my advice for providers now is to study the MLN Transmittal,” urges consultant Pam Warmack with Clinic Connections in Ruston, Louisiana.

And keep up with further revisions and clarifications from CMS as well as the HHH Medicare Administrative Contractors.

For example: In April, MAC CGS noted that for codes G0320 and G0321, HHAs should “report units as one per service (not in 15 minute increments).” And for all three codes, agencies should “report charges per the HHA’s internal policy for determining charges,” CGS said.

Another example: “Two occurrences of G0320 or G0321 on the same day for the same revenue code must be reported as separate line items,” MAC Palmetto GBA said in a May post about the telehealth reporting clarifications.

2. Check your billing system. “There are many [electronic medical record] options in the industry,” observes Elizabeth Wilson with FORVIS in Springfield, Missouri.

“The billing systems that I encounter with my clients are ready,” Warmack reports.

“We hope that agencies that perform applicable telehealth visits and their EMRs have been working to prepare to meet reporting requirements,” Wilson says.

3. Double-check your manual coding. HHAs’ billing and telehealth systems often won’t be integrated, which will necessitate manual coding, points out Linda Scott with Scott Solutions in Arlington, Virginia.

While manual coding may introduce errors, it “can be done carefully,” Scott advises. “I’d recommend daily or at minimum weekly reconciliation of telehealth encounters per the telehealth system and telehealth encounters coded to the patient record in EMR for billing,” she says.

4. Take the plunge. If your agency hasn’t implemented much in the way of telehealth and telemonitoring yet, there’s no time like the present.

“Not having any kind of telehealth program defined and in use is something I suggest agencies consider exploring,” Scott tells AAPC. Look at whether it can help “expand access, outcomes, capacity and create a reputation bump,” she says.

Bottom line: “Even without direct reimbursement, which may never exist, the benefits of telehealth might outweigh the costs,” Scott emphasizes.