Below is the next tranche of responses to the excellent questions that arrived before 4.30pm today.
Just as a general point, the COVID MBS item numbers are intended as a stop gap measure in an emergency situation such as this pandemic. They are not designed to replace standard clinical practice, which in the majority of cases, will be ongoing.
1. I am a quarantined physician, having returned from overseas after the curfew. I spent over an hour on a video consult with a complex CTP patient today. Should I use the COVID items to bill to the insurer?
The websites of many of the CTP and WC insurers have information about ensuring continuity of care for their injured policy holders during the COVID situation. For example, here is a link to the information on the TAC website https://www.tac.vic.gov.au/about-the-tac/coronavirus-update.
There is no definitive answer to this question and of course you cannot add AMA codes as you normally would, because there are no equivalent AMA codes for the new COVID codes.
Best advice is to call and speak with the insurer if you can. If you can’t, then bill using your usual item numbers, not the COVID items, and notate the claim (which will be manual) stating the service was provided via telephone/video due to COVID, and add details confirming that either the patient was a ‘vulnerable patient’ or you, the provider, was under forced quarantine.
As this claim is not going to Medicare there is no issue regarding bulk billing, and AMA rates will usually apply under the relevant State legislation.
2. What are the COVID items for case conferences such as 820 for outpatients and 880 for inpatients?
There are no COVID items for these services and you don’t need them. Case conferences can already be provided by video, face to face, telephone, or a combination of these. As the patient is not present either, there is no issue regarding patient vulnerability.
3. I work in a public hospital pain clinic where the patients are usually bulk billed to Medicare. Can we use the COVID services in our public hospital outpatient department?
Be very careful here. Public hospital outpatient billing is complex, involving the provisions of the National Health Reform Agreement (NHRA), its interface with the Health Insurance Act and your Right of Private Practice Agreements. You should:
- Follow directives from your State Health Departments
- Note that only referred services can be billed to Medicare in Public Hospital outpatient clinics under the NHRA
- If you and the other doctors in the pain clinic are all FRACP, AND salaried medical officers, AND your patients meet the vulnerable patient criteria (see bulletin No.1) then you can claim the equivalents of items 110 (91824/34) and 116 (91825/35) and conduct the clinic via video/telephone
- Any doctors in your pain clinic who are not FRACP (most commonly anaesthetists), cannot claim these items even if they are salaried. But they can claim the ‘other medical practitioner’ services described in yesterday’s bulletin – items 91792 to 91814. VERY IMPORTANT: even though these services are unreferred, YOU MUST HAVE A VALID REFERRAL, to bill to Medicare in a public outpatient department, because you must meet the requirements of the NHRA.
4. So as a Psychiatrist I can’t bill a new patient i.e. a 296 equivalent? Does that mean that new vulnerable patients can’t be seen? Or I use a lesser value code eg 308 COVID equivalent?
You can continue to see your new vulnerable patients of course. And if there is no/low COVID risk for either of you, the expectation is that you would proceed as you always would. Probably in your rooms.
If the patient is at risk or you are, then in the alternative you can claim the equivalent of items 300 – 308 (91827/37 to 91831/41) because the item descriptors have been updated so that they do not specifically state it must be a subsequent attendance – this is a welcome development since yesterday.
Do not be tempted to default to item 91831/41 because it is the highest paying service, as this is a serious offence. You must meet all the requirements of the item descriptions as always and the item 308 equivalents are 75 minutes.
5. Bulk Billing consent
- Are patients required to sign the DB4?
See yesterday’s bulletin. In a nutshell, Section 20B (3) of the Health Insurance Act has not changed. That would require parliamentary approval due to the nature of the change. So, the correct legal position is that yes, patients must sign the bulk bill voucher to evidence their consent. BUT note my comments yesterday.
- Will Medicare accept a SMS between the practice and the patient, where the patient replies YES to the question of consent to assign benefits to the Doctor.
The Government is bound by the provisions of the Electronic Transactions Act 1999 and the Commonwealth Attorney General Department website contains really great, clear legal information about how it applies. Here’s a link https://www.ag.gov.au/RightsAndProtections/ECommerce/Pages/default.aspx. Section 20B of the HIA is not exempt and therefore the DB4 form can be signed electronically and Medicare has already endorsed this approach via its existing email telehealth consent process which you can read here https://www.servicesaustralia.gov.au/organisations/health-professionals/services/medicare/mbs-and-telehealth/claiming/bulk-billing-telehealth-video-consultation. Best advice is to use the exact words from the existing Medicare telehealth process in the above link, but instead of putting the words in an email, put them in the SMS. Retain the SMS trail for 2 years.
6. Can I bill a 112 + 91824/91825 for a telehealth COVID patient (vulnerable patient NOT in a rural area or aged care facility)?
No. Item 112 can only be billed with items 110, 116, 119, 132 or 133, and will be rejected if you try to bill it with anything else.
The COVID items are designed to replace both the base item and the telehealth loading, during this emergency period.
So, for example, item 91824 = 110 + 112
7. My item numbers 3005 and 3010 are palliative care. The rebate on the alternatives offered is much less. Can I just keep using these item numbers in the interim?
You can continue using your usual item numbers only if you meet all elements of the item description, including face to face attendance, which is required for items 3005 and 3010. You must not claim these items if you did not personally attend the patient. That is a very serious offence.
Unfortunately, you will have to default to the ‘other medical practitioner’ items described in yesterday’s bulletin for the time being. If possible, continue to consult your patients as you normally would – face to face.
The Government is proactively updating and tweaking the COVID services day to day so there may be a positive change for palliative care soon. We are keeping a close eye on this and will provide relevant updates as soon as they come to hand.
Thanks again for your wonderful questions. It is a confusing time and we really hope that we are helping you to be free of ‘am I billing correctly worry?’ If you have any suggestions about how we can help you further, just let us know.
Margaret & The Synapse Team.
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