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Week 10:  Tactical pause and Telehealth

In case you had not heard, the deployment of MHS GENESIS is on a tactical pause.  Although initially paused because of travel restriction, it became apparent that the MTF priorities were going to need to shift to the medical needs of COVID-19.  Some training remains ongoing and no specific timelines have been established for what this means.  In the meantime, things have continued to change rapidly for our normal operations.  Over the last 2 weeks I’ve been more intimately involved in telehealth questions than I thought I would ever be – and I wanted to pass along what I could in a short practical way.  This is not more about telehealth as a platform.  This is simply the nuts and bolts of what I think you need to know.

 What changed.

Immediately after my post 2 weeks ago there was a cataclysmic change in telehealth.  Health and Human Services (HHS) issued a Notification of Enforcement Discretion for Telehealth Remote Communications During the COVID-19 Nationwide Public Health Emergency (https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html) There are three main things to know about this:

1.       Authorized the use of non-HIPAA complaint applications (such as Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, Zoom, or Skype) for telehealth without risk of penalty for HIPPA non-compliance

2.       Authorized the use of HIPAA complaint applications (such as VSee, Zoom for Healthcare, doxy.me, Google hangouts, Cisco Webex, Chime, GoToMeeting, Spruce Healthcare Messenger) without the need for signing a Business Associate Agreement (BAA)

3.       Waiver and Modification of Section 1135 which allows telehealth across state lines.  Some states have additional opportunities for emergency licensure as well.

What DoD/DHA has done?

At this point 3 additional options have been “approved” by DHA/DoD.  Skype, Facetime, and Duo.  I honestly have no idea why just these three have been approved, however it does appear that systems are working on activating the stores and applications for use of these programs on government systems.  Furthermore, they are activating cameras (to limited success).  They are also actively attempting to increase the number of Adobe licenses for use of telehealth for patients.  However most importantly, they have authorized the use of telehealth on personal devices. Some commands are reviewing ways to reimburse for additional charges that occur from this use.  DoD cyber security will not direct the use of alternatives on personal devices (please interpret to best meet patient and staff needs)

What do you recommend?

The situation has changed rapidly, and agility and innovation are the key to maximizing patient care while minimizing exposure.  I recommend something that is inexpensive (or free), easily accessible, cross platform, doesn’t require downloads, does not expose clinical staff’s personal information, is easy to use, is designed with healthcare in mind, and allows alternative duty locations to be used to reduce staff exposure to the virus.  I also recommend using the phone or asynchronous (messaging) when appropriate but do find tremendous value in the addition of video.  My personal choice is doxy.me (even paying the $35 for HD).  No, it is not on the “approved” list so I’m not recommending it.  I’m simply stating what I currently believe is the best choice based on my requirements.  I’ve also applied for a free vidyo license but have yet to heard back. 

How do I document this?

Before I get into how…let me tell you why.  I do believe that proper documentation of telehealth visits is incredibly important.  It is NOT because of productivity.  It is because we need to be able to understand any differences in outcome, engagement, and satisfaction for our patients and staff.  I am a huge advocate for telehealth, but we are still learning the optimal times and how to use telehealth.  I am including the guide, but here are the cliff notes:

For Synchronous Telehealth (Video) – use your regular E&M code (992**) with a -95 modifier.  For PHAs add 96160 CPT

For Synchronous Telehealth (Audio only) – use E&M 99499 with CPT 96160 and G2012

For Asynchronous Telehealth (Messaging) - use 99421 (10 minutes) 99433 (11-20 minutes) or 99423 (21+ minutes) with a -GQ modifier

Next Week: TBA

GENESIS TIPS:  You can create favorites for orders – to include E&M codes.  You can also include and bundle modifiers and CPT codes together. This makes selecting the right codes or set of codes much easier!