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…
- If you need help with an audit appeal or regulatory compliance concern, contact us at (800) 635-4040 or via email at [email protected].
- Read more about our: Total Compliance Solution
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Experienced compliance professionals. Our compliance services are structured by a chief compliance officer and supported by a team that includes physicians, attorneys and a team of experienced auditors. The team has many decades of combined experience helping protect the interests of physicians and the organizations they serve.
Quality of coders and auditors. Our US-based auditors receive ongoing training and support from our education division, NAMAS (National Alliance of Medical Auditing Specialists). All team members possess over 15 years of experience and hold both the Certified Professional Coder (CPC®) as well as the Certified Professional Medical Auditor (CPMA®) credentials.
Proprietary risk-assessment technology – our auditing team uses ComplianceRiskAnalyzer(CRA)®, a sophisticated analytics solution that assesses critical risk areas. It enables our auditors to precisely select encounters that pose the greatest risk of triggering an audit so that they can be reviewed and the risk can be mitigated.
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