Telligen, the Quality Innovation Network-Quality Improvement Organization (QIN-QIO) for Colorado, Iowa, Illinois, and Oklahoma, in partnership with the University of Colorado Practice Innovation Program, hosted a webinar and question and answer session during which expert speakers provided an overview of the CMS waiver 1135 rules as well as recommendations for coding and documentation for use of telehealth during COVID-19, so that patients can be cared for without leaving the safety of their homes.

Objectives:

• Understand the telehealth benefit under the CMS 1135 waiver, a temporary and emergency measure
• Learn about telehealth benefits for Medicaid and commercial payers
• Identify qualified and non-qualified providers eligible to bill telehealth codes
• Identify proper coding for telehealth services and when to use telehealth modifiers
• Describe proper documentation for telehealth visits

HITEQ Webinar Takeaways:

• Non-clinical eligible providers who receive portal or email questions and respond over a specified time period are able to bill to certain codes. 
• Reviewed telehealth, virtual check in, e-visits, and physician and non-physician telephone only (no video) visit coding and billing. 
• Provided ICD-10 and CPT codes for COVID-19. Should check with labs about codes to use. 
• Provided update that 3/31 guidance on place of service (POS) changed (e.g., 02 vs. 11).
• Waiver 1135 states that HHS will not conduct audits to ensure that a prior relationship existed.
• Commercial payer current policies vary by payer and are still in development. See the Center for Connected Health Policy website for guidance.
• Verbal consent is currently approved and should be properly documented. Advised that health centers should contact healthcare attorney to confirm best practices.
• “Patient-initiated” visits/communication can be difficult. Providers or health systems can outreach to patients to provide information about requesting telehealth visits. 
• How to bill uninsured patients for telehealth? No restrictions but must meet requirements of code. Can bill a straight fee for the visit. 
• Advised not to record telehealth visits at this time as there is no way to safely store recordings.