Telemedicine:

Telemedicine must not be used when face-to-face services are medically and/or clinically necessary. The distant Provider is responsible for determining that the service meets all requirements and standards of care. Certain types of services that would not be expected to be appropriately delivered via telemedicine include, but are not limited to, those that: are performed in an operating room or while the patient is under anesthesia; require direct visualization or instrumentation of bodily structures; involve sampling of tissue or insertion/removal of medical devices; and/or otherwise require the in-person presence of the patient for any reason.

Clarification:

Do you mean to include services that “require direct visualization or instrumentation of bodily structures” as a standalone statement? This suggests that needing to see edema, for example, might need to be completed in person because it requires visualization. It also suggests that if you want to see range of motion on a knee, for example, it also requires an in person visit. Please modify this language to clarify specifically what needs to be seen in person and consider that visualization is precisely what can be accomplished with video.

Originating Site Fee:

 In the event it is medically necessary for a Provider to be present at the originating site at the time a synchronous telehealth service is delivered, said Provider may bill an originating site fee (via procedure code Q3014) when both of the following conditions are met: · The Medicaid member is located at a provider office or other location where services can be received (this does not include the member’s residence); and · The Provider (or the Provider’s designee), is affiliated with the provider office or other location where the Medicaid member is located and attends the encounter with the member. The Provider or designee may be present to assist with initiation of the visit but the presence of the Provider or designee in the actual visit shall be determined by a balance of clinical need and member preference or desire for confidentiality.

Clarification:

Traditional telemedicine specifically allowed the rendering of clinical care between a patient and a remote provider. These visits are often facilitated by a nurse at the originating site (with the patient) using peripherals (stethoscope, for example, to transmit real-time heart and lung sounds). Will the need to operate a telemedicine cart and peripherals qualify as “clinical need?” There often is no clinical need for a MD/ACP to be available to provider care to the patient at the originating site; only the need for a nurse to operate the video cart and the peripherals.

Thank You:

We appreciate that you include language that will allow an RHC, FQHC, or IHC to serve as a provider site, not only as an originating site.

Documentation Requirements:

When billing for an originating site, the originating site and distant site Providers must maintain documentation at the originating Provider site and the distant Provider site respectively to substantiate the services provided by each. When the originating site is the member’s residence or other location that cannot bill for an originating site fee, this requirement only applies to documentation at the distant site.

Clarification:

If a single appointment, with a provider at a distant site and a patient at an originating site, is scheduled as a single “Joint Appointment” in an electronic health record, will the recording of that visit, including both the provider and patient site check in, intake, and visit documentation, suffice as documentation for both the provider site and the originating site? In other words, the originating site nurse will be documenting in the single Joint Appointment that is a distant provider’s visit and documentation of record? There is not a separate formal documentation of an interaction at the originating site; only the single visit with components from the distant and originating sites.

Authorized Services:

OTP/OBOT Specific Services *Initial prescriber assessment for … buprenorphine induction allowed via telehealth during the Public Health Emergency.

Clarification:

Strongly advocate that this be allowed beyond the Public Health Emergency. If an in person visit is required, this may prohibit patients seeking the care that is needed because of this requirement.