Home health agencies currently have the option to deliver some services using telecommunications technology as part of COVID-19 Public Health Emergency (PHE) waivers granted by CMS to allow more flexibility for providers to provide consistent patient care. However, the Centers for Medicare & Medicaid Services (CMS) emphasizes that telehealth services should never replace home visits and the use of any telecommunications must be in the patient’s plan of care.
Starting in CY 2023, as per the Home Health Final Payment Rule, home health agencies have the option to report telehealth encounters using three newly introduced G-codes. By July 1, 2023, reporting telehealth encounters will become mandatory for all home health agencies.
New G-codes for Telehealth
CMS aims to collect data to understand the characteristics of patients using remote health services and to identify the social factors affecting their use, including potential barriers for certain groups of patients.
At present, telehealth encounters are not considered equivalent to home visits for payment purposes. However, to increase the chances of being reimbursed for telehealth services, home health agencies must start reporting their telehealth encounters using the new G-codes.
The three new codes represent three types of telecommunications visits as follows:
G0320 – two-way audio and video
Home health services furnished using synchronous telemedicine rendered via a real-time two-way audio and video telecommunications system
G0321 – audio only
Home health services furnished using synchronous telemedicine rendered via telephone or other real-time interactive audio-only telecommunications system
G0322 – remote monitoring technologies
The collection of physiologic data digitally stored and/or transmitted by the patient to the home health agency (i.e., remote patient monitoring)
By voluntarily reporting telehealth encounters using the new G-codes, home health agencies can gain insights into their telehealth utilization, assess the impact on quality of care, and improve cost accuracy, helping to prepare for mandatory reporting starting in July 2023.
Stay Updated on Public Health Emergency Waivers
The Department of Health and Human Services (HHS) extended the COVID-19 public health emergency (PHE) for an additional 90 days on January 11, 2023, with an expected end date of April 11, 2023. HHS has pledged to provide 60 days’ notice before ending the PHE, allowing home health providers to prepare. As of now, providers expect to know by early February if the PHE will end in April.
Additional Information: Utilizing Telehealth for Sudden or Unforeseen Discharges
In exceptional circumstances where an in-home visit is not possible, a clinician may face an unexpected or unplanned discharge to end a home care case. This can occur due to a variety of reasons including unavailability of the last qualified clinician, patient non-compliance, patient moving to another location, or difficulty in finding or reaching the patient.
If all other steps in Category 2 Q15.3.6 Static Q&A have been exhausted, a telehealth encounter may be the best way to obtain accurate OASIS data. CMS Quarterly OASIS Q&A October 2020, Question 2 or CMS Quarterly OASIS Q&A July 2020, Question 4 provides guidance on utilizing telehealth for such unplanned discharges.
Ensure that your clinicians are knowledgeable and updated with the latest guidelines from the 2023 final payment rule and the OASIS-E. To maintain accuracy and compliance in documentation, leverage the expertise of your QA team and provider by seeking their support and input.
