Home Health & Hospice Week

Make sure those visits get into the PoC.

Home health agencies have a lot on their plates these days, but they should pay special attention to billing with the recently required telehealth reporting codes. So emphasized a Home Health & Hospice Medicare Administrative Contractor staffer at the National Association for Home Care & Hospice national meeting on Oct. 17.

Recap: In its 2023 home health final rule issued nearly a year ago, 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. 295). 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 had to 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).

But experts worry that with no direct reimbursement incentive tied to reporting these visits, overburdened HHAs won’t do it.

“It is imperative that home health agencies use these codes to help capture all of the ‘non visit’ time that is spent on HH patients,” urges K&K Health Care Solutions. “If we, as an industry, do not accurately use these codes to collect this data, then CMS will NEVER see the value in these types of visits,” the consulting firm warns. “This is a necessary step on the way to getting reimbursement for telehealth visits,” K&K says in its electronic newsletter.

“It is crucial to investigate these new G-codes and to report them accurately on claims,” stresses Melinda Gaboury with Healthcare Provider Solutions in Nashville, Tenn. “CMS has issued these codes to make it easier for patients to receive care at home, and it is our responsibility as healthcare providers to ensure that we report them correctly,” Gaboury says in her Monday Minute with Melinda vlog.

“Report these codes accurately to ensure CMS has the data needed to eventually provide agencies with the reimbursement they deserve for telehealth services,” Gaboury encourages.

HHAs attending a conference session from HHH MAC CGS heard the same message. “I want to make sure that you guys are reporting these,” CGS Provider Outreach and Education Manager Nykesha Scales said of the telehealth codes in the MAC’s presentation reviewing regulatory updates in the sector. “It’s now mandatory as of July 1,” Scales impressed upon listeners at NAHC’s “One Voice, Many Stories” conference.

CGS’ overview covered an array of regulatory updates ranging from potential rate cuts to Value-Based Purchasing changes, but telehealth caused the most discussion among the providers in attendance.

Why? HHAs are still figuring out how to incorporate telehealth visits into the plan of care as required, they revealed in the session. Experts previously predicted to AAPC that would be one of the major sticking points of adopting the new reporting rules (see HHHW by AAPC, Vol. XXXII, No. 22).

“It needs to be incorporated in there,” Scales confirmed in response to an   edit from the system this month, Scales noted.

But CMS has told NAHC “that they do not want [HHAs] to submit a claim if the only services provided were via telecommunications technology,” the trade group confirms. “This position is in line with CMS’ policy that HHAs are not to submit claims for payment periods without billable visits,” it says in its member newsletter.