COVID MBS items explainer and FAQs No.18, 3 April 2020


Dear Doctors and Health Care Workers

Here’s answers to today’s questions:

1.  I live in a rural area where the usual telehealth item numbers can be billed. Can I still charge a gap?

Yes, you can. There is no attempt by the Government to force bulk billing for anything other than the new COVID items.

2.  What degree of documentation do I need for the consenting of patients in order to charge COVID telephone consultation? Of course, I’m happy to bulk bill for the phone consultation which took about 20 minutes. I informed the patient verbally a few days prior to the actual phone call for telehealth being instigated and reminded the patient of such on the day the telehealth phone consultation occurred. 

Well done. It sounds like you have already done a great job keeping your patients informed.

I would suggest something along the lines of the following entries, recorded in the clinical records. Be sure to record these entries immediately after the event occurred, if possible:

Entry 1 – 1 April 2020, 10.25am to 10.30 am – “called patient’s mobile and patient answered. Explained that consult was scheduled for 2 April 2020 at 11.00am. Said it would be bulk billed as long as patient consented and that I would ask patient to confirm verbal consent during the consult while on the call, because that was a Medicare requirement. Patient said that was all fine and was happy to consent to being bulk billed.”

Entry 2 – 2 April 2020, 11.00am to 11.30 am – “[insert relevant clinical notes] at the end of the consultation I said to the patient “do you consent to assign your Medicare benefit to me for this consultation today?” and the patient replied “yes, I do.” 

This will meet the department’s current requirement for verbal consent, noting that the department has committed in writing that it will not audit this component of bulk billing during this period.

3.  How do you rate the chances that the government will audit COVID item number usage and ask clinicians to repay the Medicare rebates patients received if we charge a full private fee, include the relevant COVID number on the invoice, and process the patient’s claim online? Given the items are supposed to be bulk-billed, the government may consider we have misused the item number.

I rate this risk as very low. The Government has almost no legal ability to force bulk billing. Available options to challenge any Government initiated proceedings on this issue would probably be met with fierce opposition and strong legal defence. I know this is not ideal, and probably cold comfort, but the Government is not on a strong footing here.

I understand this is all about to change though, so please hang in there.

4.  With regards to your answer to Q three: if I conduct a telehealth consult and bill privately, “The patient should be paying your full fee upfront and then you can submit the claim to Medicare for the patient for their rebate or they can do it themselves. What item number should I be using? My understanding is item 104 or 105 both require face to face consultation. Plus, COVID telehealth codes must be bulk billed. I don’t see a way the patient can get a Medicare rebate. 

I know this is confusing. Who would have thought that one of the most basic tenets and supposedly most simple processes of the Medicare scheme, could be so legally complex? But it is. Bulk billing is a dastardly difficult little scrap of law.

Look, the Government basically has no legal authority to force bulk billing and we addressed this in our very first bulletin which you can read here.

Can I suggest you start with bulletin 1 and continue reading through them all because this bulk bill issue is a consistent theme.

All I can say is that I understand the issue will be resolved and billing will return to normal very soon. Hang in there.

5.  I am Palliative Care Specialist who bills Item 3005 and 3010.  There does not seem to be any phone or telehealth Item numbers related to these numbers that we can bill.

Unfortunately, these services are currently not included. Please review:

Bulletin 2 point 7

Bulletin 3 point 7

Bulletin 10 point 1

Bulletin 15 point 2

6.  Are there any items equivalent to 132/133 for COVID billing for teleconferencing?

No. Only 110 and 116 are currently included in the COVID suite.

7.  I am a Geriatrician who normally visits nursing homes to see nursing home residents in various remote towns. I have a large base of patients living on NSW borders, where my main practice location is. I haven’t billed telehealth before. I have heard something about telehealth codes eligibility for different geographical regions. How do I check for this?

Please review the following bulletins:

Bulletin 2 point 1

Bulletin 7 point 8

Bulletin 8 point 6

Bulletin 13 point 3, 7, 20 and 21

Bulletin 16 point 3

Thank you all for your kind words of support and engagement again this week.

We hear it’s all going to change again next week, so strap yourselves in!

Tomorrow we will do a Special Edition called “Who can order COVID pathology tests?” Because we understand the pathology companies are rejecting correct requests made by Nurse Practitioners, which is preventing patients getting COVID tests that they need. So, I’ll drill down into the law to help the pathology companies have clarity around the issue.

Until then, stay inside, stay safe and stop the spread!

Margaret and the Synapse team.

COVID MBS items Special Edition Nurse Practitioners, No. 19, 4 April 2020…Read more

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