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The outpatient hemodialysis unit Medical Director is meeting with the Facility Administrator (FA) to discuss the logistics of telehealth dialysis rounds..

Question Title

* 1. The FA questions whether telehealth visits are allowed in the outpatient setting. The Medical Director explains that CMS has broadened access to Medicare telehealth services. Nephrology can now use telehealth services to conduct billable visits with patients on dialysis. Eligible nephrology providers include

The correct answer is (b) physicians, NPs, and physician assistants (PAs), only.

Rationale: The Centers for Medicare & Medicaid Services (CMS) has expanded telehealth services on a temporary and emergency basis under the 1135 waiver authority and Coronavirus Preparedness and Response Supplemental Appropriations Act. As such, CMS has broadened access to Medicare telehealth services so that beneficiaries can receive a wider range of services. For the first time, nephrology practices can use telehealth devices to conduct visits with patients on dialysis who are treated at outpatient clinics. Previously, federal regulations only allowed such services to be used for patients on home dialysis. A range of providers, such as doctors, NPs, and PAs are now able to offer telehealth to their patients. However, services of RDs and LSWs are not billable under nephrology visits.

Center for Connected Health Policy/Public Health Institute

Question Title

* 2. According to the most current CMS waivers, nephrology practices that are using telehealth services to make outpatient dialysis rounds can bill for the same monthly visits, provided they meet which of the following criteria for a patient recently discharged home from the hospital with a recurrent GI bleed?

The correct answer is (b) One in-person visit must be made for the current month by the nephrology provider.

Rationale: As of 3/30/2020, CMS enacted emergency waivers that modified ESRD program requirements. Prior to this date, CMS had required that the ESRD dialysis facility ensure that all dialysis patients be seen by a physician, nurse practitioner, clinical nurse specialist, or physician’s assistant providing ESRD care at least monthly, and periodically while the hemodialysis patient is receiving in-facility dialysis. CMS has waived the requirement for a monthly in-person visit if the patient is considered stable. However, an unstable patient (e.g., readmission for recurring GI bleed) must be seen in-person for the month & reassessed every 30 days thereafter until deemed stable.


Question Title

* Nephrology providers using telehealth services in the outpatient hemodialysis units are permitted to use audio or video communication technology to communicate with patients during the COVID-19 nationwide public health emergency.

Acceptable non-public remote facing communication products that are permitted in telehealth interactions with patients include

The correct answer is (c) Skype, Apple FaceTime, and Google Hangouts video, only.

Rationale: During the COVID-19 national emergency, which also constitutes a nationwide public health emergency, covered health care providers subject to the HIPAA Rules may seek to communicate with patients, and provide telehealth services, through remote communications technologies. Health care providers may use popular applications that allow for video chats, including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, Zoom, or Skype. Under this Notice, however, Facebook Live, Twitch, TikTok, and similar video communication applications are public facing and should NOT be used in the provision of telehealth by covered health care providers.

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