Video or Phone Sessions during a Pandemic: Will Insurance Cover Them?
by Barbara Griswold, LMFT
UPDATED April 20, 2020
Have coronavirus concerns have led you to think about doing sessions by video or phone (aka telehealth)? You CERTAINLY aren’t alone. If you are like me, you’ve been considering it for some time, but suddenly it is your biggest priority.
Why consider telehealth?
This is a great time to consider telehealth, even after “shelter in place” orders are lifted. You will be able to see clients who are ill, who are unable to get to your office, who are homebound, and those who are traveling within the state. Plus, it enables you to meet with clients who live anywhere in the state; you are no longer limited to your area. It’s more convenient, and can save gas, time, and money, for clients and therapists. But will insurance cover these sessions?
Has insurance historically covered video or phone sessions?
36 states currently mandate telehealth coverage (see a state by state breakdown here). But even in these states, plans often imposed limitations on when it was covered. The therapist might have to be on a telehealth provider list, be in-network, and/or attest that they know state telehealth laws. Telehealth might not be covered for psychotherapy, or only if provided by a doctor, or only for certain diagnoses. A client might have to prove they couldn’t find an available provider to see them in-person. Telehealth might not be covered if provided to the client at their home or work. And only a few plans covered phone sessions.
How the coronavirus is changing the game
Just in the last few months and weeks, COVID-19 has definitely led to telehealth being more frequently covered. Many of the largest insurance plans have sent out press releases, not only encouraging telehealth but stating they are relaxing many of their previous limitations. Some are allowing telehealth for psychotherapy sessions, some now allow out of network providers to provide this service to current clients, some are allowing phone sessions, and some are dropping pre-authorization requirements. However, several plans still say they have some conditions, such as needing the therapist to be on a telehealth provider list, or to be in-network. In the past, most had insisted that therapists use a HIPAA compliant platform. Then, in a stunning announcement on 3/17/20, the U.S. Dept of Health and Human Services waived enforcement of HIPAA regulations during this health emergency, stating that “covered health care providers may use popular applications that allow for video chats, including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype, to provide telehealth” without risking that the government might impose a penalty. see complete article here
In addition, Congressional leaders recently announced an emergency coronavirus response bill that will allow Medicare reimbursement for providers using telehealth to treat seniors at home. The bill, which is pending a vote in the House and Senate, will waive Medicare’s geographical restrictions on telehealth during a public health emergency (read an article about this bill here; read the bill itself here).
How do I find out if my client’s insurance covers telehealth?
The most reliable way to find out if a client has telehealth coverage is to call their plan. This is particularly difficult right now, since phone wait times at plans are even longer than usual. Emailing the plan with questions has worked surprisingly well for me with some plans. You should provide the client’s name, date of birth, health plan ID number, even when asking general coverage questions. This is because coverage may vary depending on your state or the client’s employer account, and whether it is a group or individual plan. Some plans (e.g. ERISA or self-insured plans) have different rules and are not obligated to follow state laws.
What to ask the plan
Ask if video or phone psychotherapy sessions are covered, and ask if it is covered when provided by someone with your license. Ask if there are any conditions/limitations. Be ready to give the CPT code for the service. Note that the CPT code you will use for a telehealth service is the same at the one you would have used if it had been done in person (ex. 90834 or 90837). Ask what modifier is needed, if any (for video, it is usually 95 or GT, if needed) — check the Telehealth Policies list I’ve created (see “How I Can Help” below) to see which modifier the plan wants, and verify this with the plan when you call. Most plans want you to use the Place of Service Code 02 (telehealth) instead of 11 (office) on the claim/invoice for either phone and video sessions, though a few plans and Medicare require you to use the same POS code (11) you would use for in person sessions, so don’t assume.
So how does this charge look on my invoice or claim?
If you are billing on a CMS-1500 claim form, the place of service code goes in column 24B, the CPT code in 24D, and modifier in the first box to the right of the CPT code in 24D. The modifier or place of service code communicates that it was a telehealth session. If you are an out of network therapist billing instead by an invoice, its a good idea to have a session description to make it clear that the session was provided via phone or video. It should say something like:
4/15/20 Place of Service Code 02. CPT code 90834 Modifier 95 45 min. individual session provided via synchronous telehealth, $150
How I can help
I have been feverishly researching insurance plans and their current telehealth policies in the light of COVID-19, and have put together what I hope is a very helpful resource for you: CLICK ON THIS LINK TO SEE A LIST OF INSURANCE PLANS AND THEIR CURRENT TELEHEALTH POLICIES. Before you do, though, read the rest of this article. Remember that the policy list is a work in progress, which is being updated regularly as I get more info, so check back periodically. And you can help by sending corrections and additions (must be about psychotherapy telehealth) to me at firstname.lastname@example.org. I am most needing need direct emails from plans, plan website references, or press releases outlining a plan’s telehealth coverage to verify it’s accuracy.
Will plans pay the same as in-person sessions?
Thirty-five states currently have coverage parity for telehealth, meaning they must pay the same as in-person sessions. Four states have pending bills on the issue. Check out the state-by-state situation here
Considerations before you provide telehealth
We all can agree it is important to provide ongoing care to clients, especially during a public health emergency, and there is no doubt that video sessions are the wave of the future. But don’t just jump on Skype or Facetime and do sessions. Find out the laws in your state that apply to telehealth, and what needs to go in your telehealth consent form. Then, get telehealth training before starting. There is a lot more to learn than you might think. You’ll need to learn how this therapy is different than in-person work. There are different legal and ethical obligations when the client is at a distance, as well as clinical and technological challenges you should be ready for, and policies you should have in place before providing these services. These include how you’ll handle an emergency or technology problem, how to screen clients for telehealth, how to address confidentiality issues, insurance coverage questions, and how to bill so it is clear they were not in-person sessions. Even little things like how to look at the camera instead of your screen so the client experiences eye contact. And remember, in most cases, you can only provide telehealth if you are licensed in the state where your client is at the time of the session.
Does my documentation change?
Other than the signed telehealth consent and telehealth policies, for the most part, your documentation should be the same as for in-person sessions. However, at the start of each telehealth session you should ask a client to confirm his identity (if the session is by phone) and his exact location in case of emergency, and in the notes document that you asked these questions. Also, be sure you have an updated emergency contact on file, and that you are aware of the local police phone number and other emergency resources where the client is located. Insurance plans have been known to check to be sure you have written telehealth policies and consents as well as emergency procedures on file.
Where to get training
There is so much more to learn, and I am also just learning. So for telehealth/technology training or questions, ask the experts, not me. Check out the quick-start up courses offered by Person Centered Tech https://personcenteredtech.com/tmh/starter/ or the Telebehavioral Health Institute (THI) (https://telehealth.org/individual/). Both these websites have a lot of info for telehealth therapists. While you are there, join their e-newsletters to keep on top of the ever-changing world of telehealth and technology. And of course, for support about insurance, notes, practice building (or, these days, practice-maintaining) in these trying times, you can always schedule a phone consultation with me at www.calendly.com/barbgris — and soon I may be offering video consultations!
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