Responding to the COVID-19 emergency, the Centers for Medicare and Medicaid Services (CMS) announced implementation of new telehealth flexibility authorized by the supplemental appropriations bill that passed March 6. These changes will allow clinicians to both care for patients who may be infected with COVID-19 and to exercise caution with all patients by keeping people out of waiting rooms where they may be exposed to the virus. This is a particularly helpful tool for seniors with underlying cardiovascular conditions that are known to have poorer prognoses.

CMS's fact sheet and FAQ document explain Medicare telehealth waivers and other telemedicine program waivers in detail. Some of the services mentioned can be found in ACC's coding quick tips on the COVID-19 hub. Of note, key items for cardiovascular practices include:

• Medicare will make payment for Medicare telehealth services typically limited to the traditional Telehealth Program when furnished to beneficiaries in any health care facility and in their home. This includes E/M services 99201-99215.
• Telehealth services are not limited to patients with COVID-19, allowing telehealth as an option to manage new or existing patients remotely. An existing relationship with an established patient will not be required.
• Medicare telehealth services are billed as if the service had been furnished in-person. The claim should reflect the designated Place of Service (POS) code 02-Telehealth, to indicate the billed service was furnished as a professional telehealth service from a distant site. Additional modifiers are unnecessary for waiver telehealth services.
• Coinsurance and deductible would generally apply to these services. However, the U.S. Department of Health and Human Services (HHS) Office of Inspector General is providing flexibility for health care providers to reduce or waive cost-sharing for telehealth visits paid by federal health care programs.
• Mobile computing devices have audio and video capabilities that may be used for two-way, real-time interactive communication qualify as acceptable technology, utilizing everyday communications technologies such as FaceTime or Skype without running afoul of HIPAA Rules under enforcement discretion granted by the HHS Office of Civil Rights.
• Telehealth program waivers effective March 6, 2020 through duration of COVID-19 public health emergency.

This new flexibility should help those who are rapidly implementing telehealth in the cardiology clinic.

Keywords: ACC Advocacy, Coronavirus, Centers for Medicare and Medicaid Services, U.S., Medicare, Public Health, Severe Acute Respiratory Syndrome, Medicaid, Telemedicine

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