Insurance Billing Code for Telehealth?
Is there an insurance billing code for telehealth?
Yes, there actually are a large number of CPT billing codes that are specific to telehealth as well as a fairly extensive list that are specific to telebehavioral health. When you are ready to start delivering telebehavioral or any other kind of telehealth, ask the insurance carrier to approve you for telehealth sessions prior to delivering sessions. When billing, know which modifier to use, or not use. Use “-GT” after your normal CPT code if billing the “G” codes. When billing the “9” codes, do not use the modifier. Place of service codes are the digit “2”. Although a nuisance, it is wise to check with each insurer before billing. Once your claim is rejected, it might be too late to re-submit.
In telebehavioral health, telemental health and distance counseling, how do you obtain client signatures on relevant documents? Do you wait to have your first session until you’ve received all of it?
Signature requirements varies across practitioners, circumstances and states. Many states require informed consent prior to treatment. Some states and guidelines suggest in-person assessments prior to remote care.
In-person assessments are still mandated in many U.S. states for telemedicine, where prescriptions are written. Many of these states do not have provisions for counseling, but if you get in trouble, related legal precedents such as medical law can easily be called into play. In general, do the same as you would do in-person for most of these dilemmas and you will be the safest.
If you are not seeing your client/patient in-person at any point, you have options. Some platforms are offering document services as part of their suite of features. You can simply click a link to upload your document to their portal. Your client/patient gets an email which asks them to come to the protected, HIPAA-secured portal to view and sign the document. When that is complete, you get an email telling to you the document is signed. Another option is to purchase a separate document signing services. Just be sure that the one you select offers HIPAA-compliant services and gives you a Business Associate Agreement (BAA) that protects you from their failures. If you prefer to not use a digitized system, but rather, just want to stick with printed forms, you can upload them to your website or other document storage service, ask them to download the forms, print, sign and send them back to you by snail mail or secured email. (Asking them to sign, scan and send these documents by unsecured email could be considered a security violation by HIPAA unless you have a prior informed consent regarding unsecured email. Our suggestion then is to be cautious with unsecured email.) Document exchange services are also available online, but many are not HIPAA-compliant. You can search Google to find one that is HIPAA compliant and affordable for your purposes.
Is It Wise to Record Telehealth Sessions?
What if client or patient records your session? Do they have to tell you? Should you verbally address this issue at some point?
Although some clients/patients may have special needs that can best be served by making recordings of their sessions, clients/patients can also easily forget, lose or somehow compromise themselves with their own telehealth recordings. They may be dismayed and possibly hold you responsible for having their telehealth recording appear at inopportune times or in the wrong hands.
The simple truth is that you cannot prevent a client/patient (or other people in their environment) from recording your telehealth sessions. However,, your informed consent process can make your policies clear. Through that process, you can obtain their agreement to avoid all recordings. While telehealth informed consent is required by most U.S. states and most Canadian provinces, it must be done very carefully to fully protect everyone involved. It is wise then, to fully understand telehealth informed consent processes that work as well as those that don’t work.
It is also important to be alert for and pick up on any clues that recording is occurring. It also wise then, to think through what you will say or do if you realize that a client/patient is recording your session. Practice such statements with a colleague. Just as you probably did in your graduate or medical training, you will probably learn a lot by actually doing it versus just thinking about it.
This current discussion may also serve as a simple reminder that we already we well into the 2st Century. Everything that we say and do can be recorded without our knowledge by a client/patient sitting three feet away from us in a brick-and-mortar office. We have to be prepared to address such realities as professionals to maintain our boundaries and protect all parties to the best of our abilities. Shrugging off these legal mandates is not a wise course of actions. If in doubt, it is best for you learn telehealth best practices through training and/or consultation, then experiment with one or a small group of colleagues. Use different platforms and modalities (email, video, texting, apps etc.). Make as many mistakes as possible while you are in training, so as to know how to handle them when they arise with someone who is counting on you to be competent. As with most technology, if an event can fluster you, it will. Learn best practices, identify what you need for the people you serve and then, practice ahead of time.
Recording Telehealth Sessions?
Should clinicians make telehealth recordings of treatment sessions?
Telehealth experts all too often tell stories about how treatment recordings or documents get into the wrong hands. As licensed professionals, we each have to decide how to handle the issue of telehealth recording, given our respective clients/patients and interventions.
Greater Potential for Loss of Control with Recording Telehealth
Since 1959 when telebehavioral health, telemental health (also known as behavioral telehealth) research began, the best practice has been to avoid recording a session unless it is court ordered — or if the recording is secured and serves a specific purpose that is agreed to by both parties (i.e, hypnosis, supervision).
All in-person principles related to recording apply to telepractice, except that using technology adds greater potentials for loss of control and wider dissemination of recordings.
Professionals can lose or misplace their own recordings. Storing recordings to the “cloud” can pose unexpected problems as well because most automatic computer cloud storage system are not HIPAA-compliant. You automatic settings then, can be uploading all your recordings, correspondence and other saved files to the unsecured cloud on a weekly or daily basis without your direct knowledge.
We simply can’t predict with any accuracy where they might go over time if we have not sought specific training in how to assure confidentiality (i.e, HIPAA-compliant storage processes and services if you practice with U.S. residents, or PIPEDA if you serve Canadian clients/patients.) Many other countries have such privacy and/or security laws. In general, the legal places to record anything from your computer include: 1) a HIPAA-compliant cloud, 2). a thumb drive or 3) a backup system in your brick-and-mortar office, and 4) an online video provider that you have vetted very carefully, and from whom you have obtained a valid Business Associate Agreement (BAA) to protect both your clients/patients and yourself.
© 2018 New Jersey Association of Osteopathic Physicians and Surgeons
The Journal is the official magazine of the New Jersey Association of Osteopathic Physicians and Surgeons (NJAOPS). NJAOPS is the sixth largest state affiliate of the American Osteopathic Association. NJAOPS represents the interests of more than 4,700 active osteopathic physicians, residents, interns and medical students. Founded in 1901, NJAOPS is one of the most active medical associations in New Jersey with 12 county societies.