In the process of billing insurance companies for medical services, most physicians either authorize hospitals they serve, to manage their billing through reassigned benefits (billing rights), or prefer managing it themselves, many also outsource it from third parties.
However, when hospitals partner with a telemedicine company, with a network of physicians spread across various locations, an ideal solution is to allow the telemedicine provider to take over the responsibility.
Not many hospitals prefer to bypass their well-established billing operations to allow a third party billing company to run the operations for them. But the variability of telemedicine policy as it exists in different states, and the spike in COVID-19 cases, makes it a best practice that needs to be considered.
Revenue cycle management too being an important element of collecting revenue for most hospitals, most administrators reluctantly consider the feasibility of partnering with a third party RCM company, and turning over the revenue controls to them.
Telemedicine Over the Years
Traditionally, telemedicine was used by hospitals to deliver specialty care to patients. Hospitals around the country have stroke specialists, who are on-call to assist with life-saving decisions regarding tPA administration. Emergency departments that have staff shortages of mental health clinicians to meet patient demand, seek the services of remote TelePsychiarists, to offset the shortage of on-site psychiatric support.
Tele-specialists also assist rural hospitals in multiple medical specialties, located in remote areas; these hospitals are insufficiently staffed, and rely on the services of tele-specialists.
Currently, due to the pandemic, telemedicine is the only means through which hospitals large or small, urban or rural, are delivering care to COVID-19 patients.
Reassignment of Billing Rights
Not many health professionals may be aware of what entails reassignment of billing rights for a physician. While the billing staff of hospitals understand the basics of how services of a telemedicine provider have to be billed, not many billers may be in the know of how Medicare has to be billed for telemedicine service,
For instance, the place of service would be considered the home state of the tele-physician, not the hospital where the patient is being treated.
Likewise, if a patient located in Montana seeks the services of a TeleNeurologist based in California, the Medicare billing requirements would entail the hospital to bill the Medicare Administrative Contractor or “MAC” for California, and not Montana. For those who are not aware, MAC is a private health care insurer that has been awarded a geographic jurisdiction to process Medicare.
Telemedicine Billing Compliance
In compliance, it entails the rendering provider working for the hospital to be enrolled with Medicare through their home MAC, and the hospital receiving the billing rights reassignment from the physician is enrolled in the provider’s home MAC. Therefore, hospitals adopting a distributed tele-physician model may potentially need to enroll in multiple MACs nationwide to meet telemedicine billing compliance.
These are some of the telemedicine billing errors that inadvertently happen in billing offices of hospitals, since telemedicine largely due to COVID-19 has only recently made its advent in the service menu of many hospitals, and billers are yet to get familiar with all the associated inter-state regulatory considerations required for telemedicine billing.
An audit by the U.S. Department of Health and Human Services’ Office of the Inspector General (OIG) of 191,118 paid claims in 2018 determined that 31 percent of claims did not meet Medicare’s conditions of payment. Billions of dollars in paid claims are recovered each year by CMS from hospitals through audits. It’ll be a matter of concern for hospitals, if they do not meet the reassignment and billing compliance associated with telemedicine services.
Telemedicine Billing Policies Under Process
With many aspects of telemedicine policy yet to be clearly defined, telemedicine billing complexities have to be meticulously accomplished, through effective communication with payers and regulatory agencies.
Hospitals establishing telemedicine billing for contracted tele-physicians face significant risk, considering the aggregates of legal and regulatory considerations for compliance. Similarly, doctors that reassign their benefits become severely and liable, according to OIG.
As the popularity of telemedicine expands, increased attention will be focused on telemedicine billing, and claims will be scrutinised with greater diligence, and quite likely any mistakes will result in painful audits, and diminishing profits.
Hospitals will have to evaluate their needs, whether it would be prudent to manage telemedicine billing inhouse or partner with an accomplished billing company.
Reassignment of Billing Rights
In order to avoid financial risk or cause disruptions to their billing and credentialing operations, hospitals implementing telemedicine programs must consider delegating reassignment of billing rights to an experienced telemedicine billing company.
When delivering care across state lines, the complexity of telemedicine policy has to be thoroughly understood, and hospitals and physicians have to be absolutely familiar and comfortable with the variables of telemedicine billing rules, before shouldering the associated risks.
Any telemedicine provider that chooses to deliver the services through its inhouse revenue cycle management processes must ensure that it is undemanding and uncomplicated, without any inherent risks of disrupting their routine healthcare operations.
