The Centers for Medicaid and Medicare Services (CMS) recognizes the place of service code ’02,’ which allows telehealth as a place of service. Codes licensed dietitians can use to bill insurance include 97802, 97803, and 97804, which are recognized as billable with telehealth according to the CMS website. Other codes can be seen in the same link (if you are a healthcare practitioner reading this who isn’t a dietitian).
Certain requirements must be met, including using secure software for teleconferencing up to HIPAA standards, an approved originating site, and being an approved distant site practitioner. According to the CMS website on page 2, an approved originating site can be a physician or healthcare practitioner’s office, which means wherever the practitioner defines his/her office, the telehealth requirement can be met.
Other approved originating sites include “hospitals, critical access hospitals (CAHs), rural health clinics, federally qualified health centers, hospital-based or CAH-based renal dialysis centers (including satellites), skilled nursing facilities (SNFs), and community mental health centers (CMHCs).”
Additionally, the same previously mentioned link also states registered dietitians or nutrition professionals, depending on who is allowed to practice in your state and receive insurance reimbursements, are eligible practitioners to furnish telehealth services.
Other non-dietitian distant site practitioners can be “physicians, nurse practitioners (NPs), physician assistants (PAs), nurse-midwives, clinical nurse specialists (CNSs), certified registered nurse anesthetists, clinical psychologists (CPs)*, and clinical social workers (CSWs)*.” *CPs and CSWs have limitations.
Unfortunately, dietitians in private practice can only perform telehealth services if the beneficiary (the patient) is at an originating site. This means patients must still go to their healthcare practitioner’s office to receive the service. Private payers (non Medicare/Medicaid insurance) may have their own rules, but often Medicare is the example.
You should check with your private payer for their rules if interested in telehealth over traditional face to face services.
Real time communication, as opposed to delayed communication like email, must be used unless in Alaska or Hawaii. If billing, a modifier ‘GT’ or ‘GQ’ must be used. The former states that the service was done “via interactive audio and video telecommunications systems” whereas the latter states it was done “via an asynchronous telecommunications system.” (same reference link above)
Both the originating site and the distant site practitioner receive payment.
While it is important that communications remain secure, I had hoped telehealth would be implemented in a way that could save healthcare costs and improve access. Since the originating site must be one of the aforementioned sites (assume for security, not sure), telehealth is still not as convenient as it could be.
A patient must still go to an originating site rather than being able to have the service done via webcam from the convenience of their home or their office.
On the plus side, distant site practitioners can partner with the aforementioned healthcare originating sites to provide covered services. This DOES improve access for people in rural areas who may not have as easy access to specialists who are allowed to receive reimbursement for telehealth.
At Nutrition and Fitness Professional, LLC, we are available to work with healthcare practitioners who wish to refer their patients via telehealth for medical nutrition therapy (codes 97802, 97803, 97804) and use Google Meet as our secure HIPAA compliant video conferencing platform as well as other G Suite approved HIPAA compliant apps.
It is not necessary for the originating site to have access to G Suite in order for the service to be performed as the client only needs to click on a Google Calendar link.
For specific questions, please contact us.
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