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Resolved Telehealth - incident to question

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AngelaG_61163

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Incident-to Telehealth Supervision - Is this an approach open to us during the Covid emergency that we use to bill out supervising MD rates instead of NP?
 
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Telehealth Regulations Waiver


The new laws give the Health & Human Services (HHS) Secretary the authority to waive certain restrictions on telehealth during a declared public health emergency. As of March 30, 2020, the Secretary has waived requirements in several different areas:

  • Originating site: The Secretary has waived the “originating site” requirement for identified geographic areas designated an “emergency area.” Under normal conditions, a beneficiary must travel to an actual site of care – the originating site -- to receive telehealth services, but the waiver authority allows beneficiaries to receive services wherever they are. Because of the COVID-19 public health emergency, the Secretary has also waived the geographical site restrictions on Medicare telehealth services to allow all areas and locations within the country delivery of these services, including patients’ homes.
  • Device Type: The Secretary has loosened restrictions on the types of devices that can be used for telehealth services so that personal phones and tablets may be utilized, provided that the beneficiary has both audio and visual feeds to the clinician. Practitioners are able to use everyday communication technologies such as FaceTime or Skype during the COVID-19 public health emergency without breaking HIPAA rules.
  • Patient and Service Eligibility: Both new and existing patients may now access telehealth for a wide range of services. Previously, telehealth was available for a fairly limited range of services and required that the provider or another practitioner within the provider’s practice had provided telehealth services to the patient within the past three years. Now, new patients can receive telehealth services. Although the telehealth expansion still requires informed consent and beneficiary initiation of the encounter, the changes significantly increase the number of patients who can take advantage of telehealth services.
All other telehealth regulations, including the list of “qualified providers” remain in effect. Thus, ASHP’s understanding is that pharmacists can provide telehealth services incident to a Medicare-eligible provider, but cannot directly bill Medicare for these services
 
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