Question: The hospital in our health system is entertaining the idea of becoming a telemedicine hub for specialists, allowing target hospitals to have access to these specialists through a real-time, Internet-based, interactive audio and video system. The physician would be able to interview the patient, observe the patient, view vitals and X-rays either by direct visualization on a monitor or through verbal report and, with assistance on the remote side, use a stethoscope. There appears to be a way for the telemedicine physician to bill for these services. Could you outline the methodology and both the opportunities and limitations associated with it? Would I need to be a hospital employee?
Answer: These two documents from CMS cover the basics on billing Medicare for these services:
- http://www.cms.hhs.gov/Transmittals/downloads/R790CP.pdf (start at page 7)
In brief, you code the appropriate CPT code with a “GT” modifier to indicate the interactive telemedicine component (There also is a GQ modifier, but this is for asynchronous communications and can only be used for providers in demonstration projects in Hawaii and Alaska). Payment is the standard payment based on the Medicare fee schedule.
The “originating facility,” the hospital in your case, also gets a facility fee. (So, it’s theoretically OK for the physician to not be employed by the hospital, just as for any service performed at the hospital. That’s Medicare’s rule; you’ll want to know what constraints the hospital plans to set on its own.)
The originating site must be in a non-MSA county or HPSA. The patient has to be present and participating (virtually). The provider’s license must (of course) cover whatever services are provided.
These are Medicare’s rules. You’ll want to call your other major payers to see what their rules are and if they cover telemedicine at all.
The other rub I can think of is figuring out what demand might be and for what sort of services. Since your providers would have to leave the clinic, commute to the hospital, wait for the machines to start up, etc., it’s a time waster if you are billing a bunch of 99212s. Of course, you might do it anyway if there is an ethical drive to help rural populations or something.