Quarantines, office closures, and public safety concerns regarding COVID19 created a huge demand and sudden surge of telehealth services. Telehealth has long served a small subset of the therapy population, but it’s never been widely reimbursed or accepted by insurers. Now that carriers have started to reimburse and offices are able to evaluate how their patient’s fare with the new therapy model – is it here to stay? Can we go back now?
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Telehealth: How’s it going? Increasing COVID numbers in March and April left many providers and insurers scrambling to get telehealth underway in their clinic. Telehealth has always been an excellent medium for certain patients, but it has never been the norm, and many therapy clinics did not even offer telehealth before COVID. While specialists were researching the technology and reaching out to patients, insurers were also evaluating their own policies and releasing many, many memos on what they will or will not cover as it relates to telehealth.
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With the World Health Organization officially labeling Coronavirus as a pandemic and confirmation of the virus multiplying throughout the states, Insurance Companies and Public Health Organizations are getting serious about what it’s going to take to battle this – not just medically, but also organizationally and administratively.
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EEP had a great time attending ASHA and it was so great to see several of our current clients and meet many other new providers! We were able to speak to providers in all situations from all states and learned a lot about the wants and needs of the community.
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In March of 2019 Centene announced they were going forward to purchase WellCare in a $17.3 billion-dollar transaction. Since the announcement there’s been some anxiety in provider circles about what this merger could mean for providers everywhere. Centene and WellCare are two of the largest health insurers in the United States and—not surprisingly—their merger creates some uneasiness about provider bargaining power and patient choice.
The Centene/WellCare merger is not complete but is on track to finalize at the beginning of 2020. Shareholders of each company voted to approve the deal overwhelmingly, but the two companies still have a long road ahead. Ultimately the purchase must be approved by insurance regulators in 26 states. So far, it’s been announced that the companies have conditional approves in Alabama, Arkansas, Kentucky and Missouri. It has not yet been announced whether other states have approved the transaction, but Centene indicated they would not be providing updates on all steps along the way – so it’s not surprising.
Ultimately the companies will also need approval from the Department of Justice to ensure that the acquisition doesn’t violate any antitrust laws. All we know thus far is that the DOJ requested additional information about the merger which is not uncommon in large transactions like these. Lobbying groups and large organizations are speaking up to the DOJ about the merger. The American Hospital Association indicated to the DOJ that the merger “threatens to reduce competition in delivery of Medicaid managed care and Medicare Advantage services to tens of millions of consumers across broad swaths of the country.”
In Florida specifically the two companies have such a large market share that it may be difficult for them to get approval without some divestitures and that has already been acknowledged by Centene themselves. It remains to be said what concerns or comments Florida’s insurance regulators have to say about the deal. Currently there have been no public statements.
It’s unclear what this merger could mean for the actual processes and contracts that providers have with these insurers. It has not been announced whether Centene’s processes and contracts would completely replace WellCare’s. For therapy providers in Florida it’s a particularly important question. In Florida Sunshine pays therapy through a capitated model (via American Therapy Administrators) while WellCare pays fee-for-service. If Centene’s process takes over it could mean a large portion of Medicaid enrollees’ therapy will now be handled by ATA through a capitated model which has larger repercussions for provider network adequacy and patient care.
Providers may want to write the Florida Insurance commissioner about their individual concerns with this merger. Also consider joining discipline specific lobbyist groups that will help you raise your individual concerns. As it stands until more is announced about the transition and regulatory approvals are finalized it remains to be seen what repercussions this merger may have.
Waiving deductibles and copays has always been a hot-button issue in the medical community. It can be difficult as a provider to charge a patient a copay if you feel they’ve been down on their luck and hurting financially. After all – especially therapy providers – seeing them week to week you can become close to them and sometimes providers just “feel bad” charging a copay.
But choosing whether or not to charge a copay is more than a personal decision – it’s a legal one. Especially for Medicare or Medicaid patients, refusing to charge a copay can get you in hot water. The Office of Inspector General has come down hard and very clearly on the routine waiving of copays. The OIG has stated, in a special fraud alert, that a “practitioner or supplier who routinely waives Medicare copayments or deductibles is misstating its actual charge” and has also insisted that waiving copays violates the anti-kickback statute. Even if you are not physically handing a patient cash for walking into your door – waiving their copay is very similar. By waiving their copay, you’re giving them an incentive to come to your practice instead of going elsewhere. That’s providing a kickback for them to come to you.
Aside from Medicare and Medicaid patients, it’s also important for you to charge commercial patients their due patient responsibility for the insurers you’re in network with. You have legally binding contracts with these carriers that require that you bill the patient exactly what is stated on the EOB – no more or no less. Charging less – and the insurance company becoming aware of it – could easily lead to contract termination. Some states also have laws on the books that extend the anti-kickback statutes to all patients, regardless if they are Medicare or Medicaid, so you could be violating Federal law as well.
So when is it okay to waive a copay? Depending on your contract with commercial insurance carriers, it may never be okay. Please be sure you reference it before coming to any agreement with any commercially insured patient. But for Medicare or Medicaid patients there is a way to do it on a patient by patient basis when appropriate. First you need to make sure you are not doing it across the board – you need to have stated, specific and consistent circumstances by which you will waive copays and they must be based on a patient’s individual financial need. Make sure you have a waiver on file that documents the patient’s financial needs, accompanied by your office’s policy – ideally with income requirements.
It’s so important to file federal and state guidance when it comes to running your practice. Minor issues like patient copays can get a practice into serious hot water and copays are not worth losing your practice over.
Billing for Pediatric Therapy and ADOS Testing – There is so much diagnostic and standardized testing that goes into pediatric therapy. It requires a lot of documentation and time that is integral to creating a successful care plan for a patient. A common question that arises from clinic owners and providers of pediatric therapy is about ADOS (Autism Diagnostic Observation Schedule) testing and whether speech therapists can be paid for the screening and documentation around it.
Please note that this article is focusing on ADOS testing if you feel you or a speech therapist employed by you is capable of doing the test and making that diagnosis. This article is not insisting that ADOS testing is appropriate to be done by every office or every situation. ASHA’s official stance is below.
Speech-language pathologists who acquire and maintain the necessary knowledge and skills can diagnose ASD, typically as part of a diagnostic team or in other multidisciplinary collaborations, and the process of diagnosis should include appropriate referrals to rule out other conditions and facilitate access to comprehensive services.
There is no specific procedure code for ADOS testing. Instead, ADOS testing falls under two developmental testing codes.
96112: Developmental test administration (including assessment of fine and/or gross motor, language, cognitive level, social, memory and/or executive functions by standardized developmental instruments when performed), by physician or other qualified health care professional, with interpretation and report; first hour
96113: Each additional 30 minutes, should your testing exceed 1 hour
These codes cover both the actual test administration andthe reporting and interpretation that follows the test. You’ll want to be sure that you track your time spent both with the patient and working on the report afterward as they are both reimbursable.
Before billing these services you’ll want to ensure they are included in your fee schedule with any insurances you are in network with. Please note that these codes are not covered under the pediatric therapy fee schedule for Florida Medicaid and Florida Medicaid may require any diagnosis to be PCP-driven.
As a therapy billing agency with over 25 years of experience, we understand that billing can be complex, intimidating, and confusing. It is also perhaps the most important function you have to perform as a practice owner; after all, accurate and timely billing is at the core of a thriving practice.
Even if you’ve decided that you need outside help with all tasks related to billing, choosing a trustworthy agency is not a straightforward task. Below, we share our master tips for choosing a billing agency. Read on to get the scoop.
We’re confident that following the above recommendations will lead you to the right fit. How do we know? Find out more about what EEP offers, above and beyond the accuracy and integrity you should expect from a therapy billing agency.
