HOME HEALTH: Face-to-Face Encounter Must Be Audio/Video Telehealth
Question: I submitted an RCD F2F telehealth visit that was denied. Palmetto states the visit must be both audio and video. The F2F took place on 04/10/2020. The claim is being non-affirmed. Is there any way around this? Not sure how to proceed with this claim. The SOC was 03/16/2020.
Answer: The physician or an allowed non-physician practitioner must use audio/video telehealth that allows for real-time interaction between the physician/allowed practitioner and the patient as required by the SS Act. There is no way around this requirement.
Reference: COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing (June 2, 2020) (HOME HEALTH section, page 57)
FAQ – Answer: The face-to-face encounter, as described at 1814(a)(2)(C) and 1835(a)(2)(A) of the Social Security Act, can be performed via telehealth in accordance with the requirements under 1834(m)(4)(C) of the Social Security Act (SS Act). Under the expansion of telehealth under the 1135 waiver, beneficiaries are able to use telehealth technologies with their doctors and practitioners from home (or other originating site) for the face-to-face encounter to qualify for Medicare home health care.