Telehealth was always the future. Suddenly, it’s the present. Is your office ready for the pivot to remote treatment?

California workers’ comp providers may continue to treat ill and injured employees remotely during the COVID-19 outbreak. Treatment delivered via telehealth is 100% payable, using the appropriate billing codes and supported by proper documentation. Knowing the current guidelines and regulations is the first step for providers navigating this transition.

More regulatory specifics and guidelines are surely forthcoming from the California Division of Workers’ Compensation (DWC). As of the date of writing, here are three crucial things your office should know:

Edit 5/14/2020: On 5/7/2020 the California Division of Workers’ Comp Administrative Director, George P. Parisotto, issued a new Order retroactively changing the reimbursement calculation for telehealth services. Some of the information on this page may not be correct, depending on the date of service. For the latest reimbursement rules, consult the latest Administrative Orders here and check our dedicated COVID-19 page for updates.

1. Telehealth Is a Facility “Place of Service”

While telehealth pre-coronavirus was on the cutting edge of treatment options, it is well-established enough to address virtual places of service.

In 2017, the DWC adopted the Centers for Medicare and Medicaid Services (CMS) Place of Service Code ‘02-Telehealth.’ As CMS categorizes ‘02’ places of service as “Facility” places of services, the Official Medical Fee Schedule (OMFS) calculates reimbursement using the Facility Practice Expense Relative Value Units (RVU).

Accordingly, on the CMS 1500 billing form, populate Box 24B with the ‘02’ code for “Facility” place of service.

For Box 32 of the CMS 1500 billing form, providers should use the physical address at which they normally treat workers— even if the provider is currently working from home in lieu of physically going to the office.

2. Use CMS Telehealth Billing Codes

The OMFS may evolve to include California-specific telehealth billing codes, or it may not. For now, we suggest that providers should adhere to the CMS-approved telehealth billing codes available on the CMS website under List of Telehealth Services, payable under the Medicare Physician Fee Schedule.

DaisyBill clients can check the exact reimbursements for each code in their respective locations using the appropriate DaisyWizard calculator.

3. Telehealth Documentation

To help ensure proper reimbursement, providers offering telehealth treatment should document the following for all injured workers:

1. The technology utilized to render services. Whether it’s a telephone call, conferencing software like Zoom, or social tools like FaceTime and Google Hangouts, document the platform used.
   
   State regulations only vaguely describe telehealth delivery methods as “information and communication technologies” which include “synchronous interactions and asynchronous store and forward transfers” in Buildings and Professions (BPC) Section 2290.5. Until there’s more regulator precision, simply document the delivery system.
   
2. Any time spent outside of the rendered telehealth service. Remember, providers are allowed to bill 99358 for all of the additional non-face-to face time the provider spent to coordinate care for the injured worker, including additional time spent:

1. Reviewing other provider’s medical records,
2. Consulting between treating physicians,
3. Coordinating a Request for Authorization and reviewing utilization review decisions

3. Patient consent. BPC Section 2290.5 is clear:
   
   “...the health care provider initiating the use of telehealth shall inform the patient about the use of telehealth and obtain verbal or written consent from the patient for the use of telehealth as an acceptable mode of delivering health care services and public health. The consent shall be documented.”
   
   Patient consent may be verbal or written. While there is no specific guidance for verbal consent, we advise including the following language once consent is granted:  

“The patient consented to telehealth medical services being provided virtually via: XXXX”

As state regulatory bodies work out the details, workers’ comp providers should embrace the DWC’s call to “consider creative solutions appropriate to providing care to injured workers.” DaisyBill is here to support providers in navigating the billing and payment aspect of this historic challenge.

Email us your questions. As we continue this blog series on telehealth for workers’ compensation, we’ll research and answer your questions.

To learn about why E-billing is critical during COVID-19 and the details of how workers' comp E-billing is different from group health or Medicare, sign-up for our free upcoming webinar below.

For more on telehealth rules for Medicare, California health insurers, and California workers’ compensation, look through the free resources available on our COVID-10 page.

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