Anesthesia Business Consultants, LLC (ABC), a leading provider in billing and practice management for the anesthesia and pain management specialty, reiterates that prevention of the spread of COVID is essential during this time. Treatment from a distance is one of the strategies being employed in the pursuit of that goal.
Telehealth has been one means of limiting the spread of the virus. This involves performing certain traditionally face-to-face services by means of technology that allows for social distancing. Some of the more recent telehealth provisions have allowed providers to bill a myriad of codes, such as those reflecting evaluation and management (E/M) services and critical care, without actually being in the same location as the patient. From a strict sense, telehealth has historically referred to virtual visits between provider and patient by means of real-time, two-way communication that must contain both audio and visual components. So, while you’re not physically present with the patient, you are both speaking with them and seeing them, such as with Skype or FaceTime on an iPhone. Beginning last week, however, the visual requirement was removed, at least for “certain” services, according to the following CMS announcement:
Since some Medicare beneficiaries don’t have access to interactive audio-video technology that is required for Medicare telehealth services, or choose not to use it even if offered by their practitioner, CMS is waiving the video requirement for certain telephone evaluation and management services, and adding them to the list of Medicare telehealth services. As a result, Medicare beneficiaries will be able to use an audio-only telephone to get these services.
Despite this new provision, telehealth may not be applicable to anesthesia providers in the hospital setting as one of the key conditions of billing a code under the telehealth umbrella is that you and the patient must be in separate locations. In other words, telehealth does not come into play if you and the patient are in the same facility.
So, for anesthesia providers who are at the hospital, but who want to remain outside of patient rooms in order to reduce the risk of viral spread during certain services, such as postoperative pain rounds or certain critical care services, there are limited options. Some have looked at the telephone code set (CPT 99441 – 99443) as a possible solution. With last week’s regulatory changes, these services are now paid at rates that approach reimbursement levels for “regular” E/M services. However, in most cases, these calls must be patient initiated (though at least one state Medicaid has lifted this requirement and one Medicare administrative contractor has suggested this would not be necessary on a recent call). However, the audio-only calls can present certain hurdles. For example, you cannot bill this service where the call results in a decision to see the patient within 24 hours, or where the call refers to an E/M service within the previous seven days or within the postoperative period of a previous procedure.
Tony Mira, President and CEO of Anesthesia Business Consultants, alerts readers that “Despite these hurdles, anesthesia providers in the hospital setting can get paid for some of their services in a virtual setting.” Let’s look at three examples:
Postoperative Pain Rounds (Non-epidural)
Unless you are rounding on a patient with an indwelling epidural catheter, postoperative pain rounds will typically involve the subsequent hospital care code set (99231-99233). This code set requires that you document two out of the following three elements: (a) Patient History, (b) Patient Exam, and (c) Medical Decision-making (MDM).
From a practical perspective, you cannot perform a physical examination of a patient without seeing the patient. So, you won’t be able to document the exam bullet. However, relatively new E/M rules allow you to meet the history element by simply reviewing the patient’s history that was obtained, in-full, by ancillary staff (you should document such review). In addition, you can perform and document the MDM element of the service without being present with the patient. In such a scenario, you will have documented two out of the three elements required to bill a “regular” (non-telehealth) E/M round.
- Rounds on Epidural Catheter When submitting a daily pain round, CPT 01996, remember that you are being paid to evaluate/manage the epidural itself, as well as the patient. You might typically inspect the insertion site, look at and/or change the dosage settings, determine if there are any issues with the catheter, etc. In other words, you need to be in the room to fully perform this service. If you choose not to be in the room while rounding on such a patient, we recommend billing this service from the subsequent hospital care code set, listed above. Again, you will still need to document your review of the patient’s history and your medical decision-making.
- Critical Care Services Another scenario that is presenting itself to our clients during the NHE is critical care. Technically, it may be possible to perform such services without physically seeing the patient since these are time-based codes, and part of that time can include non-patient-facing services. However, this may not prove to be of practical value—at least in many cases—since much of what anesthesia providers are being asked to perform in the ICU requires them to be at the patient’s bedside.
We don’t know how long the need for limiting exposure to COVID patients will persist—whether through the use of PPE or rounding from a distance. Yes, some facilities will soon be opening up to so-called elective surgeries, but that doesn’t mean that the risk of COVID infection will be completely gone. Indeed, we’re being warned of an “inevitable second wave” by leading experts. Therefore, even as surgeries ramp back up, some will want to continue to practice under conditions that will limit the virus’ ability to spread. Virtual rounds, then, may be an option chosen by many anesthesia providers well into the fall.
Anesthesia Business Consultants (ABC), established in 1979, is the nation’s largest billing and practice management company dedicated to the complex and intricate specialty of anesthesia and pain management. ABC’s quality reporting program for all clients is able to ensure compliance with MACRA and can be extended to cover any quality initiatives requested by payers or the facility. Our registry allows participation and successful compliance with the MIPS measures, ensures providers are protected from payment adjustments and offers bonuses for successful reporting. Join the 20,000,000+ patients and 17,000+ anesthesia clinicians already reporting their performance through the MiraMed certified registry program.
The heart of our perioperative suite of products is ABC’s proprietary practice management software F1RSTAnesthesia. F1RSTClient, the premier client portal, allows clients secure and seamless access to ABC’s applications. F1RSTAnalytics, our powerful suite of dashboards and reports, provides “Insight at Your Fingertips,” offering real-time data prowess and providing the data to aid in operating your anesthesia practice as an effective clinical organization and successful business. Our solutions provide accurate, prompt and complete billing and revenue cycle management. Our exclusive focus improves your cash flow and profitability. Visit ABC at: www.anesthesiallc.com.