The Medicare system is under an ‘Emergency Declaration’ due to the Coronavirus Pandemic. This means that certain home health regulations have been relaxed and some requirements have been changed to prevent the interruption in home health care. All temporary changes to home health regulations can be accessed here.
Home health agencies can augment in-person visits using telecommunications technology for remote clinical services within the 30-day period of care, as long as it’s part of the patient’s plan of care and does not replace needed in-person visits ordered on the plan of care. The use of video-conferencing or telephone calls - 'telehealth' - may result in changes to the frequency or types of in-persons visits outlined on existing or new plans of care.
As part of its response to COVID-19, Medicare has TEMPORARILY expanded the role of telehealth in the delivery of home health care. There is no scheduled end-date to when telehealth will not be allowed.
Telehealth versus Telemedicine
'Telehealth' is the process of conducting a meeting with 
a patient – using video software or the telephone – to collect information from the patient on her/his healthcare needs and to provide teaching and consultation.
'Telemedicine' includes Remote Patient Monitoring - allowing remote caregivers to monitor patients that reside at home by using mobile medical devices to collect data (e.g. blood sugar or blood pressure). Telemedicine permits providers to share patient data with a practitioner in another location.
Balance Telehealth and In-Home Visits
The primary use of telehealth by HHAs is to reinforce patient teaching and elicit patient recall of teaching, which, in addition to in-home visits (to complete the physical assessment), facilitates timely discharge.
Benefits of Telehealth
Patients can provide a verbal update on the status of their disease processes and clinicians can provide teaching. Home health agencies may be able to reduce the number of in-home visits by using telehealth to reinforce teaching and elicit the all-important patient recall necessary for discharge.
Drawbacks of Telehealth
1. Patient’s don't receive a physical assessment. Since a physical assessment is not performed, a comprehensive picture of the patient's clinical condition is unknown.
2. HHAs can NOT bill for a telehealth session. Only in-home visits can be reported on the final claim.
3. If using video conferencing, health care workers also have to act as technology-support personnel to patients and/or families that may not be technically-savvy.
Steps to Implementing Telehealth
1. Modify your Treatment Consent Form to include telehealth sessions.
2. If video-conferencing is to be used, provide explicit instructions on how to use the video-conferencing product.
3. Give patients a list of symptoms they should be prepared to report, teaching plan and recall items on the first visit after admission.
4. The CMS485 must include how and why telehealth will be used. For example:
SN 3w1, 2w2, 1w1 plus telehealth via telephone or, if patient is able, video-conferencing 1w4 to review teaching and recall of disease management
Avoid these Pitfalls
1. Patient is Confused. Don’t include telehealth in the careplan if the patient is confused and there is no teachable caregiver.
2. Don’t Under-Utilize. Medicare specifically states that telehealth cannot be used in place of in-person visits. Additional Document Requests (ADRs) and Medicare audits are often triggered by low or high utilization as reported on the final claim.
3. Keep it simple and use a telephone. Telehealth does NOT need to include video. You CAN keep it simple by keeping the session to telephone-only. Although viewing the patient, and the patient being able to view the clinician has its merits, assisting the patient/family to execute a video-conference may take more time and effort than is reasonable.
A Beginner's Guide to Home Health Billing
