There is much miscommunication regarding the use of telehealth services to report risk adjusted diagnoses. In the early days of COVID-19, CMS stated that it would pay for telehealth services that were conducted in an interactive format using both audio and video telecommunications. When issues regarding seniors’ (and providers’) lack of access to real-time video calls were escalated, CMS relaxed the standard for telehealth visits to only audio (such as a telephone call). However, this is for fee-for-service Medicare visits.
The standard for risk adjustment (MRA) is still a face-to-face visit, and due to the public health emergency, now includes telehealth via interactive audio AND video. This must be clearly documented on the note and coded with either place of service code “02” or modifier “95.” A telehealth visit using only audio may be payable by CMS for a Medicare beneficiary, but this visit will not count for logging MRA diagnoses for Medicare Advantage patients and ACOs.
Providers must document that the patient gave consent to the telehealth (audio/video) visit.
Attached is a memo from CMS for your records.