Telehealth reimbursement

Bi-partisan HEAT Act would pay home health agencies for virtual visits during public health emergencies

Up to half of the total number of visits made to home health patients each 30 days could be virtual visits reimbursed by Medicare under the terms of a new bi-partisan bill.

Proposed legislation known as the Home Health Emergency Access to Telehealth (HEAT) Act was introduced in the U.S. Senate on Friday by Sen. Susan Collins (R-Maine) and Sen. Ben Cardin (D-Maryland). A similar version was introduced in the House by U.S. Representatives Roger Marshall (R-Kansas), Terri Sewell (D-Alabama), Jody Arrington (R-Texas) and Mike Thompson (D-California).

The HEAT Act would allow telehealth reimbursement for home health agencies during the remainder of the Covid-19 pandemic as well as during future public health emergencies.

“This is a long-awaited and much-needed bit of good news for home health and we are hoping to see this bill passed quickly,” said J’non Griffin, President of Home Health Solutions, a Simione Coding Company.

“The pandemic has highlighted the overall importance of telehealth to good patient outcomes – and particularly during an infectious disease outbreak. But thus far into the public health emergency there has been no means of reimbursement for telehealth services agencies have been providing to Medicare beneficiaries.”

Paid or not, virtual is common

The Centers for Medicare and Medicaid Services (CMS) reported that more than 12.1 million Medicare beneficiaries received a telemedicine service between mid-March and mid-August. More than 34 million telehealth services were provied across the healthcare spectrum between March and June of this year – a whopping 2,500 percent increase over the same period during 2019. Despite the lack of reimbursement, home health agencies were among those relying on telehealth for patient care.

“Even though virtual visits are not currently billable, home health agencies have had to rely on telehealth services since the earliest days of the pandemic as part of their infection prevention and control efforts,” Griffin said. “With PPE (personal protective equipment) shortages and the need to protect both patients and staff, virtual visits became a necessity, billable or not.”

Report the cost of virtual visits

Cost reporting has offered home health agencies the only real means of identifying to CMS the overall cost to the industry this year of unpaid virtual visits, Griffin said – but because many agencies do not effectively use cost reporting, it may be difficult to obtain a total accurate cost.

“We remind agencies that the cost of virtual visits will need to be included on their cost reports, and that it is important to be as accurate as possible in doing so,” Griffin said. “We know how critically important these cost reports are to what happens regarding reimbursement because we saw how CMS used our cost reports to create the PDGM payment model. We need to be dedicated as an industry to accurately capture the cost of our telehealth services.”

Griffin said this a good time for agencies to prioritize their overall cost reporting, and make certain the costs of telehealth services are captured, because new requirements have recently been issued by CMS for the home health cost report.

Agencies will be required to provide much more detail in the breakout of visits, patients, salaries, benefits, contract pay and hours by discipline and payer, she said. The new requirements will be retroactive for home health agencies and home health agency-based hospices with fiscal years beginning on or after Jan. 1, 2020. Read more about the cost reporting changes here.

Need help with cost reporting?

Simione Healthcare Consultants, the industry’s largest preparer of cost reports, has specialized in cost reporting since 1966 and is available to help agencies with understanding the new requirements as well as completion of timely, accurate and affordable cost reporting. Get a free quote and read more about Simione’s cost reporting services by clicking here.

F2F, POC documentation is important, too While the proposed HEAT Act makes its way through Congress, home health agencies should continue to be careful in how they use telehealth, and how they document any virtual visits, Griffin said. "CMS has been very specific in saying that telehealth visits may be part of the episode of care if those services are tied to patient-specific needs identified in the comprehensive assessment, but virtual visits must not replace routine visits to the patient's home," she said. The Plan of Care must also include specific documentation indicating how the use of telehealth for the visit is expected to help achieve goals for that patient.

"Cookie-cutter wording about how this is part of the overall infection control measures the agency is taking during Covid-19 won't be enough," Griffin said. "There must be documentation in the POC that is specific to the patient and to his or her specific goals." Griffin said home health agencies should also be diligent in making certain documentation of telehealth visits shows compliance with CMS requirements for both audio and visual.

A CMS public health emergency waiver issued in the spring enabled the use of telehealth for face-to-face encounters, but physicians must document that the encounter took place with both audio and visual components.

“Without that documentation from the physician, agencies could be at risk for a denial based on lack of a valid face-to-face,” Griffin said.