With the advent of the Covid-19 pandemic many chiropractic offices are facing cancelled appointments and even temporary closure. Though it may have limited application in a chiropractic setting, telehealth could be a way to keep patients and providers safe while still possibly generating a little revenue from delivering healthcare from a good social distance. It could improve patient compliance by enabling patients to interact with providers when it may be difficult or impractical to see them in person.
In response to the Covid-19 pandemic the HHS Office for Civil Rights (OCR) announced on March 17, 2020, that it will waive potential HIPAA penalties for good faith use of telehealth during the nationwide public health emergency. This means that non–HIPAA approved technologies like Skype and FaceTime can be used. (See this link for more details.)
Many private payers recognize the potential cost savings and improved health outcomes that telemedicine can help achieve, therefore they are often willing to cover it. However, not every state has enacted parity laws which require private payers to cover telemedicine to the same extent as face-to-face services and the rules about how it is enforced vary from state to state. See the latest from the Center for Connected Health Policy to see if your state is included. Things are changing daily in response to the pandemic.
It appears that all of the states with parity laws require private payer reimbursement for live video encounters, while only some require coverage for asynchronous, or store-and-forward encounters. Note that typically audio–only interaction is not covered. This includes:
A text only email message
A fax transmission
An audio-only telephone consultation
Some states leave the rules up to the payers. And, in some cases, small group or work comp plans have the option to opt out. Be sure to check with your state and the health plan before attempting to bill for telemedicine.
Review this guide on billing for telehealth encounters from the Center for Connected Health Policy to get the comprehensive overview on billing, but the guidelines that might be more relevant to chiropractic follow.
When billing for telemedicine the place of service code that goes in 24b on the 1500 claim form should be 02 to indicate telehealth. Typically the 95 modifier should also be attached to the CPT code. (See Appendix P of the CPT code book for AMA’s full list of telemedicine-eligible codes.) Medicare has two of their own modifiers, depending on the type of telehealth. Some private payers may recognize them, therefore they are included below. The options are:
Modifier GQ: Via an asynchronous telecommunications system (for Medicare)
Modifier GT: Via Interactive Audio and Video Telecommunications systems. (for Medicare)
Modifier 95: Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications System (reported with codes from CPT Appendix P)
The guidelines for modifier 95 are as follows:
Synchronous telemedicine service is defined as a real-time interaction between a physician or other qualified health care professional and a patient who is located at a distant site from the physician or other qualified health care professional. The totality of the communication of information exchanged between the physician or other qualified health care professional and the patient during the course of the synchronous telemedicine service must be of an amount and nature that would be sufficient to meet the key components and/or requirements of the same service when rendered via a face-to-face interaction. Modifier 95 may only be appended to the services listed in Appendix P. Appendix P is the list of CPT codes for services that are typically performed face-to-face, but may be rendered via a real-time (synchronous) interactive audio and video telecommunications system.
