Dear Doctors and Health Care Workers
Thanks to everyone who has reported successful experiences charging gaps for COVID services, following which patients have successfully obtained their Medicare rebates. Whilst interesting, this represents nothing more than how Medicare has always been designed to work, and has always worked.
Where is Stage 4? No announcements today and therefore, as at right now, no new law in relation to COVID MBS services – disappointing. So, in summary, nothing has changed since 23rd March 2020, but we will keep watching over the weekend in case an announcement is made.
Here are answers to today’s questions.
1. Is there any update regarding use of palliative care specialist item numbers 3005. 3010?
No, no updates as at today, unfortunately. The only option remains to avail the ‘other medical practitioner’ items. See Bulletin 2.
a) If we start consults via telehealth into high risk inpatient rooms, how can we bill?
- You can’t bill using the COVID MBS services for admitted patients unfortunately, because inpatient services remain completely excluded.
- If your patients are in a private hospital you can charge a private fee with no rebate, see Bulletin 6.
- If your patients are in a public hospital and have elected to be treated privately you could also charge a private fee with no rebate, but please check with the hospital any relevant policy position.
b) Any update regarding the multidisciplinary team billing?
You probably don’t need COVID updates for these services, as most item numbers within this category can already be billed using video, phone, face to face or a combination of these. If you can let me know the specific item numbers, I will be happy to have a closer look for you. In the meantime, please see Bulletin 3, point 2.
c) OT, Physio, Dietitian for high risk cancer patients?
OTs already have psychological COVID services available – Items 91172,3 and 91185,6. Nothing for Physios or Dieticians yet.
2. I am a Psychiatrist and regularly bill items 344 and 346 for family group therapy. Is there an equivalent for COVID-19? If not, can I use another item such as item 306 for the single patient equivalent?
There are two parts to this question:
Firstly – No, there is no COVID equivalent for any group therapies at the moment.
Secondly – As you would know, items 344 and 346 are for group therapy and include an individual consultation of a person that takes place on that day, and who forms part of the group.
So, as long as you provide a consultation service to one of the members of the group (i.e you meet the item descriptor of say item 306), then there is no barrier to you claiming that item or its COVID equivalents – items 91830 and 91840 – as long as other vulnerability criteria are also met.
3. I am a Psychiatrist and am set up to consult my patients via videoconferencing and charge them a gap over the Medicare rebate. Could you please advise the COVID MBS code number for the same?
STOP! This is more complex than you think. Please do not proceed without reviewing the Psychiatry COVID codes and the legalities around bulk billing and charging gaps for these services. We have described key requirements in Bulletins 1, 2, 3 and 6. Please review and come back with any questions.
4. For the COVID 19 telehealth codes, what is the mandatory documentation. Is there anything in addition to usual clinical notes?
The usual requirements under the Health Insurance Act 1973 for practitioners to record and retain ‘adequate and contemporaneous’ records remain in force. So, no changes to your regular requirements. But do you have to record any of the following, which would seem relevant in the current crisis?
- Start and end time of call – There is currently no legal requirement for this, but it is a good idea, and will provide evidence that you met the requirements of any time based items.
- Mode of telehealth (VC vs Phone) – No, not required. The item numbers themselves indicate whether it was video or phone.
- People present on the call – Not a current, specific legal requirement but definitely best practice and recommended. Would fall within the scope of adequate and contemporaneous records.
- Patient verbally consented to the telehealth consult – in the event we are asking for exemption to the DB4. – See yesterday’s bulletin (final point) with an update about this from the Department. Yes, record whatever evidence you have that the patient consented to be bulk billed.
5. We are a rehabilitation private billing clinic, normally bill AMA rates, items 132 and 133. Our appointments generally last 1 hour. We have noted that a physician who is at risk of COVID-19 can telehealth all their patients, however, billing 110 and 116 does not match the time we spend with our patients and we are not going to bulk bill a 110 initial for 60 minutes work on the phone. Is it correct that:
a) We still can’t charge a gap for COVID telehealth?
Yes and No. See Bulletin 1 regarding the legalities around this and Bulletin 6.
b) There are no telehealth COVID items equivalent to 132 and 133 so we can’t bill them?
Correct. There are no equivalent COVID items for these services at this time. But let’s hope we hear news of a solution next week.
That’s a wrap for this week everyone. I thought I would end the week by sending a heartfelt message of gratitude and thanks from the Synapse team to all of you on the front line. #clapforourcarers has spread through our company just as it has throughout the NHS and the world.
Stay safe everyone. Till next week.
Margaret and the Synapse team.