Reimbursement Update: Proof of Delivery and Telehealth
on June 11, 2020
By Ronda Buhrmester, Sr. Director of Payer Relations & Reimbursement
This article was first featured in Essential Advantage Q2 2020
An important topic that comes up when providing services for patients during the public health emergency (PHE) reimbursement. Reimbursement is essential to all providers, especially now. As providers are adjusting the ways in which they provide services for their patients, it is important to note proper reimbursement guidelines.
The information below refers to Medicare Fee For Service (FFS) rules. If you’re dealing with a payer outside of Medicare FFS, these requirements may be different. You will need to reference the payer’s guidelines during the PHE. Visit https://www.vgm.com/coronavirus/billing-reimbursement/healthplanpolicychanges/ for information on health plan policy changes during COVID-19.
Proof of Delivery (POD) for Shipping
If you are providing a delivery via shipping or delivery service, be sure to follow the following guidelines in order to receive proof of delivery (POD):
Delivery via shipping or delivery service directly to beneficiary
- Beneficiary’s name
- Delivery address
- Delivery service’s package identification number, supplier invoice number or alternative method that links the supplier’s delivery documents with the delivery service’s records
- Description of each item delivered
- Quantity delivered
- Date delivered
- Evidence of delivery
- Get Confirmation of Delivery = these are not stored with shipping service (USPS, UPS, FedEx) supplier is responsible for saving in the patient file
All the dots need to connect between shipping, delivery, and billing
- Mastectomy supplies are listed under non-consumable supplies. This means for any supplies being shipped using a shipping service or by direct delivery, the request for refill guidelines must be documented.
Some important items to note include the shipping invoice. Use the shipping invoice that transpires and tracking number on there. When the item does actually deliver, you get a confirmation of delivery with same tracking number that corresponds on the shipping invoice. You will need to keep this in the patient’s file. The claim can then be submitted for payment.
It is important to pull the confirmation of delivery from the shipping service. These confirmation numbers get recycled, so be sure to pull that information from their website to be stored in the patient’s file.
Telehealth has been approved in place of the in person visit with an approved telehealth provider during the PHE. Approved telehealth providers include Physicians, Nurse Practitioners, Clinical Nurse Specialists, and Physician Assistants. Under the Interim Final Rule (IFR) that recently came out, additional practitioner such as NPs or PAs are accepted by Medicaid to write orders, as long as it is within their scope practice.
“Is Telehealth Acceptable via telephone?”
For home medical equipment, the best form and best practice for telehealth visits is both audio and video. For mastectomy, audio via telephone is acceptable in situations where patients may not have access. It is recognized that patients may not have access to a smart phone or other technology where video communication would occur. The IFC allows physicians and other practitioners to bill for certain telephone assessment, evaluation and management services during the PHE. These services were previously not separately billable. These services may be billed for both new and established patients.
Please note: regardless if telehealth is used in place of an in-person visit, ALL coverage criteria are still applicable and medical necessity must be documented in the medical record to justify the items provided.
Telehealth Acceptable Format and HIPAA/BAA Compliance
According to the Office of Civil Rights (OCR), it is important to note the acceptable formats for telehealth, including, but not limited to, Skype for Business, Updox, VSee, Zoom for Healthcare, Doxy.me, Google G Suite Hangouts Meet. If you are conducting any of your business through telehealth-style appointments, including virtual fittings, we encourage you to use applications that HHS recommends. If the application does not require a HIPAA business associate agreement (BAA) in connection with the provision of the application, HHS encourages providers to notify patients that these third party applications potentially introduce privacy risks and providers should enable all encryption and privacy modes when using these applications. More information can be found on the HHS website.
For any reimbursement questions about telehealth and POD, please contact Ronda Buhrmester, Sr Director of Payer Relations & Reimbursement for VGM & Associates, at (217) 493-5440 or Ronda.Buhrmester@vgm.com.
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