Once again CMS muddies the water during the PHE and I guarantee their auditors won’t know this! Thanks to Stephanie Allard, CPC, CEMA, RHIT, of DoctorsManagement for raising this point with me today!

Updated (7/28/20) COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing / pg. 71 Question 33 regarding consent by patient for telehealth, e-visits and audio only. CMS now states the following, “Consent may be obtained at the same time the service is furnished. Similar to services furnished in person, the patient’s consent is not required to be noted on the medical record for telehealth services furnished using interactive audio-video technology.” The portion regarding consent not having to be noted on the medical record… has been added.

Prior to this it read, “Beneficiary consent should not interfere with the provision of non-face-to-face services. Annual consent may be obtained at the same time, and not necessarily before the time, that services are furnished.”
Please make a note of this in your files in the event of an audit where the auditor denies your service(s). You now have black & white language to support your appeal!

What to do next…

  1. If you need help with an audit appeal or regulatory compliance concern, contact us at (800) 635-4040 or via email at [email protected].
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