DO’S and DON'TS for Telehealth HCC Risk Adjustment

CMS has approved risk adjustment for diagnosis captured via telehealth with a brief press release for all encounters that would meet risk adjustment criteria had they been face to face. As this rule is novel in its scope and application we’re hearing quite a bit of chatter and confusion around the nuances of implementing these new policies. 
​
 ​We’ve reached out to our experts and have compiled a list of Do’s and Don’ts in the hopes of resolving some of the confusion. 
​

Telehealth Risk Adjustment Do’s

1. EDS Submissions: For EDS/EDPS  that have been provided via telehealth, use place of service code “02” for telehealth or use the CPT telehealth modifier “95” with any place of service.
2. Interactive Communication: Ensure all telehealth services use interactive audio and video telecommunications system that permits real-time interactive communication. Both the provider and the patient must be able to see and speak to each other during a telehealth encounter. 
3. Documentation Standards: Ensure all telehealth service documentation meet the required “M.E.A.T.” standard for EDS submissions. Telehealth exceptions are not documentation exceptions, the note must meet the standards of a face-to-face encounter. ​
4. Approved Providers: Ensure all telehealth providers meet the same “approved provider” standard as face-to-face encounters. These include approved specialists as well, not just PCPs.

Telehealth Risk Adjustment Don'ts 

1. EDS Submissions: Report services to the EDS that have been provided via telehealth using face-to-face inpatient or outpatient codes or fill place of service with placeholder codes other than what CMS has stated. 
2. Wait for face-to face encounter to document for diagnosis: Don’t code for conditions that do not have the required “M.E.A.T.” in documentation simply because they were discussed over a telehealth encounter. Providers should also be weary of documenting for physical exams that can not be conducted via telemedicine to satisfy the evaluation or assessment portions of the note. 
3. Telephone Communication: Audio only communications such as traditional telephone calls do not meet the telehealth requirements, CMS has separate submission codes for telephone encounters. Diagnoses from telephone or other audio-only encounters should not be submitted for risk adjustment until they have a telehealth or face-to-face encounter reconfirmation. ​
4. Other health care personnel: Submit codes for HCCs captured by other (non-approved) healthcare personnel such as a Registered Nurse to conduct telehealth encounters.