Creating a telehealth audit checklist: 5 ways to ensure compliance and mitigate risk

May 3

Telehealth continues to play an important role in ensuring access to healthcare services during the COVID-19 pandemic. This is true for physicians in all specialties and especially those working in mental health. However, the expansion of telehealth has not been without coding and billing compliance challenges. There are complex payer-specific rules to follow, and many of those rules continue to evolve over time. Now, the Office of Inspector General (OIG) is taking a closer look at telehealth compliance to ensure healthcare providers meet all requirements. This article provides a five-step telehealth checklist for providers to help them stay on track.

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1. Make sure it’s a ‘telehealth-covered’ service. Medicare is easy because it posts a list of services payable under the Medicare Physician Fee Schedule when furnished via telehealth. However, you’ll need to contact each commercial payer and Medicare Advantage plan to find out whether these same CPT codes are payable when rendered via telehealth.

Also note that some telehealth codes are only covered until the Public Health Emergency Declaration ends. However, Medicare is covering some of these codes permanently. This quick reference guide summarizes temporary and permanent changes to telehealth billing so you can focus on telehealth compliance.

2. Use a HIPAA-compliant telehealth platform. Second on the telehealth checklist for providers is a HIPAA-compliant platform. Although some payers permitted (and still do permit) flexibility in terms of the type of telehealth platform you can use, best practice is to use one that that protects patient data. Cyberattacks are on the rise, and medical practices are at risk. Having a cybersecurity plan for telehealth is paramount.

3. Pay attention to place of service codes and modifiers. This is an important part of any telehealth audit checklist for billing. Medicare, Medicare Advantage, and commercial payers may each have different requirements. For example, for new or established patient telehealth office visits, report either place of service (POS) code 10 (patients with Medicare are in their home while receiving telehealth services) or POS 02 (telehealth provided other than in the patient’s home). If the telehealth office visit is for COVID-19-related care, report modifier -CS (cost sharing waiver) as well.

However, other payers may require POS code 02 and/or modifier -95, -GQ (telehealth service rendered via asynchronous telecommunications system), or -GT (telehealth service rendered via interactive audio and video telecommunications system). To ensure telehealth compliance, it may be helpful to create a grid that lists each payer along with any requirements for POS codes, modifiers, and any additional documentation. Add this grid to your telehealth audit checklist for billing, and be sure to reference it before claims go out the door.

4. Focus on documentation integrity. Detailed physician documentation should include the following: Patient consent for telehealth, patient’s location at the time of the encounter, physician’s location at the time of the encounter, time and duration of the visit (Note: Only bill for the time the physician—not other clinical staff—spends with the patient), method of communication (i.e., audio or audio/video), what was discussed and why, patient’s level of risk, any data the physician considered, and what tests (if any) the physician ordered.

Note that documenting method of communication during the telehealth encounter is very important. Why? Medicare, for example, requires the use of audio-visual technology for certain telehealth services and permits audio-only for others. If you use audio-only technology for a patient with Medicare (or any other payer that hasn’t relaxed its audio-visual requirements during the current PHE), be sure to bill a CPT code from the 99441-99443 range for telephone services.

5. Monitor telehealth denials. If one of your payers changed its telehealth policies, would you even know? Maybe it’s a newly required modifier, new documentation requirements, or a waiver that has expired. A denial might be your first clue that something important has changed. Monitoring telehealth denials helps medical practices avoid continued errors that can jeopardize revenue integrity.

Conclusion
Telehealth has been a lifesaver for many medical practices nationwide, and it’s something that will likely continue indefinitely. Medical practices trying to create a long-term strategy to continue offering telehealth services must make coding and documentation compliance a part of their plan. That starts with creating a telehealth audit checklist and using it on a regular basis to ensure compliance. To learn more about how edgeMED can help, read about our telehealth-friendly software and revenue cycle management service.