OPPA submits testimony on ODM's Proposed Telehealth Rule
From Dr. Jewell's written testimony:
"Let me begin by saying that the OPPA has previously provided written comments on the proposed rule, agreed with much of the draft rule, and applauded the efforts of ODM to address concerns in the current rule. The new verbiage, the use of the term telehealth, the increased variety in approved locations for both patient and practitioner, and the allowances for increased accessibility are all of great benefit to psychiatrists, Community Mental Health Centers and patients. Hopefully, the changes proposed in the draft rule will be a win-win, and will address the supply and demand problems."
In our previous written comments, the OPPA expressed concerns about case managers not being included in the draft and stated that “it is critical that case managers have the ability to bill for services using telehealth. We cannot minimize the value and importance of their input on the multidisciplinary team and the role they play in communicating critical information from patient to practitioner."
"Upon further review of the proposed language after submitting our previous comments, it came to our attention that in the initial draft the “Appendix to rule 5160-1-18” (which defines “Services reimbursed through Telehealth”) restricted the billing codes that could be used for initial evaluation to 99201, 99202, and 99203, and the billing codes that could be used for follow-up appts to 99211, 99212, and 99213 (covering only medical decision making of up to low complexity). That meant that the higher paying codes (99204, 99205, 99214, and 99215), used for patients requiring medical decision making of moderate-to-high complexity could not be used."