Continued Access to Telehealth Services in 2021 — Reimbursement for Health Services Provided via Telehealth
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This bulletin governs Carrier reimbursement expectations for health services delivered via telehealth in Massachusetts and provides guidance to commercial health insurers, Blue Cross and Blue Shield of Massachusetts, Inc., and HMOs on implementation of Chapter 260 telehealth requirements.
Carriers must reimburse in-network chronic disease management and primary care telehealth services at no less than the in-person rate through January 1, 2023.
Carriers must reimburse in-network behavioral health telehealth services at no less than the in-person rate.
Carriers may continue paying all providers at existing telehealth reimbursement rates and, if altering rates where allowed, must file implementation plans with the Division detailing methods, timing, communication, and training.
Telehealth Reimbursement Criteria
Telehealth reimbursement criteria
Minimum reimbursement parity requirements established by Chapter 260 and described in this Bulletin:
ALL of the following
ALL of the following
- Requirement: Reimburse in-network primary care and chronic disease management telehealth services at no less than the in-person rate through January 1, 2023.
ALL of the following
- Requirement: Reimburse in-network behavioral health telehealth services at no less than the in-person rate (no expiration date stated in the Bulletin).
ALL of the following
- Requirement: Reimburse at no less than the in-person rate through the expiration of the 90-day period following termination of the Commonwealth's COVID-19 state of emergency (per Chapter 260).
ALL of the following
- If a Carrier alters telehealth reimbursement rates where permitted, the Carrier must file an implementation plan with the Division describing the methods and timing that would apply to affected providers, the timing of communication, and training for consumers and providers to ensure adequate transition time and coordination of telehealth versus in‑office visits.
ALL of the following
- Carriers may require providers to submit claim documentation demonstrating patient history, chief complaint, exam details, and medically supportive documentation for the level of E/M billed; carriers may evaluate CPT code documentation and require documentation for reimbursement.
ALL of the following
- Governor Baker terminated the Commonwealth's COVID-19 state of emergency as of June 15, 2021; Chapter 260 references the 90-day post-termination period for default parity for other providers, but the Division allows Carriers to continue existing telehealth rates or to file implementation plans to alter rates where permitted.
Coding and Documentation for Claims
| Carriers may evaluate CPT code documentation and level of E/M service coding based on documented visit complexity and time. |
Provider Requirements and Filing Obligations
Submit complete visit documentation to support E/M coding
Carriers may require providers to submit claim documentation demonstrating patient history, chief complaint, exam details, and medically supporting documentation for the level of E/M billed; carriers may evaluate CPT code documentation and require documentation for reimbursement.
- Documentation should explain the patient history, chief complaint, and exams for office and outpatient visits
- Carriers may review whether the documented reason for the visit medically supports the extent of the exam, discussion time, and complexity of the visit and assessment
- Providers may be required to present claim documentation for the encounter to qualify for reimbursement
File implementation plan if altering telehealth rates
If a carrier elects to alter telehealth reimbursement rates where allowed, the carrier must file an implementation plan with the Division describing methods, timing, communication, and training for affected providers and consumers.
- Plan must highlight the methods and timing that would apply to all affected providers
- Plan must describe timing of communication and training to be used with consumers and providers to allow coordination of telehealth versus in‑office appointments
Statutory Reference
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