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Getting Started with Telehealth

Note: This content is informational only and not intended to endorse any specific products or services. For additional information on telehealth services, watch "Telehealth: Opportunities for RDNs" in the Power of Payment video series.

First Steps

  • Check with your professional liability insurance carrier to ensure your policy covers providing MNT via telemedicine. (The professional liability insurance offered through the Academy's Member Advantage Program — Proliability administered by Mercer Consumer — does not exclude telehealth/telemedicine services.)
  • Determine your needs for cyber and data breach coverage. The use of telehealth exposes providers and organizations to additional risk of cyber theft and data breaches of sensitive client information. General and professional liability insurance does not protect providers from damages that may result from cyber/data breaches.
  • Familiarize yourself with the telehealth policies with any payers for whom you are a network provider.
  • Ensure that you are providing services in accordance with your state laws and regulations.
  • Licensure:
    • If you are licensed in the state where the patient is located, there are no additional requirements.
    • If you are not licensed in the state where the patient is located, you are likely to be required to become licensed either (1) to provide MNT to clients or patients in that state or (2) to be eligible to provide nutrition care services via telehealth in that state. You should review the laws and requirements of each state where your patients are located.
    • In addition, there are often specific rules requiring a license to provide telehealth services to Medicaid beneficiaries. Medicaid waivers to these requirements must be requested by the individual state that wants to use them. Contact your state department of health, state dietetics board, or state medical association for up-to-the-minute information in your state.

Telehealth Platform/Vendor Selection

You will need to use communications technology that complies with payer requirements to provide MNT to your patients remotely. While Medicare and several payers may have relaxed requirements during the public health emergency, it will be important to verify any policy updates related to communications technology. Services delivered via the telephone may not be included as state laws and payer policies typically require audio-video interactions. Medicare is permitting audio-only delivery for MNT services (97802-4, G0270), when audio and visual are not possible, through December 31, 2024. Make sure to get clarification from private payers and state Medicaid programs regarding the ability to provide MNT telephonically.

  • If you are currently using a practice management system or electronic health record, check with the vendor about telehealth functionality.
  • Carefully review Business Associate Agreements for any telehealth platforms you are considering. Understand who has access to, and owns any data generated during a patient visit.
  • Ask colleagues what telehealth platforms they are using. Inquire with other Academy members via DPG list servs and the Reimbursement online community.
  • Consider ease-of-use for both the RDN and clients.
  • Consider whether you need a document sharing feature in a telehealth product.
  • Get clear on the pricing structure (e.g., monthly rate, subscription, per visit fees).
  • Confirm you have internet service that is optimal for supporting any telehealth platforms or any approved temporary communications technologies. The amount and speed of the internet connection, along with Wi-Fi signal strength where utilized, will impact the video quality and amount and speed of data transfers.
  • Compare the technical support available from telehealth vendors.

Understanding Telehealth Technology Options

During the public health emergency, the Department of Health and Human Services Office of Civil Rights allowed the use of any non -public Facing Communications Technology to provide services via telehealth. However, with the end of the PHE, health care providers will be required to provide telehealth services through technology vendors that are compliant with the Health Insurance Portability and Accountability Act, also known as HIPAA. The Department of Health and Human Services has additional resources on telehealth compliance with HIPAA.

Additional notes about selecting technology platforms:

  • RDNs should seek clarification with commercial payers and Medicaid programs regarding rules and standards.
  • Ensure you and your client/patient have adequate battery/power and bandwidth if using cell phones or tablets.
  • RDNs providing MNT via telehealth will need to identify a telehealth platform that meets standard HIPAA and payer requirements. The list below includes some vendors that represent that they provide HIPAA-compliant video communication products and that they will enter into a HIPAA BAA:
    • Skype for Business / Microsoft Teams
    • Updox
    • VSee
    • Zoom for Healthcare
    • Doxy.me
    • Google G Suite Hangouts Meet
    • Cisco Webex Meetings / Webex Teams
    • Amazon Chime
    • GoToMeeting
    • Spruce Health Care Messenger

Workflow and Patient Care

Review and update all processes associated with appointments. Streamline processes. Try to use the same processes for in-person and telehealth visits (e.g., registration, obtain insurance information, share policies, obtain consent, documentation, issue receipts and superbills, and collect payments).

  • Investigate options for HIPAA-compliant electronic communication if not already established.
  • Obtain client consent to provide services using telehealth. The Center for Connected Health Policy’s online Policy Finder has information about state requirements regarding consent to provide services using telehealth visit.
  • Review the Office of Civil Rights announcements regarding temporary adjustments under HIPAA.
  • Confirm that MNT provided via telehealth is a covered benefit (in addition to verifying benefits and the coverage details for MNT) under each patient's individual insurance policy.
    • Clarify patient copayments and cost sharing for MNT or any other services you provide via telehealth.
    • Billing instructions may differ (with the same insurance company) based on the type of individual plan a patient has (commercial, self-funded, Medicare Advantage, or other type). Clarifying billing instructions for services provided via telehealth can help to ensure accurate payments.
  • Review and update policies as applicable.
  • Conduct a practice session before using any new platform.
  • Update voicemail, website, and social media to let your patients know your practice is now offering telehealth services.
  • Provide instructions or "tips" to help your clients access telehealth services based on your practice's technology to maximize appointment time and avoid disruptions to care.
  • Consider data collection for the purposes of demonstrating effectiveness of your services when they are provided using telehealth.
    • If you are already collecting data for outcomes evaluation in your practice and using both in-person and telehealth modalities to provide MNT, consider taking steps that will allow you to sort, analyze and compare outcomes based on the delivery modality. Practice level data may be helpful in your own contract negotiations.
    • Academy members have free access to ANDHII, a registry that enables RDNs to track nutrition care outcomes and advance evidence-based nutrition practice research. ANDHII can help you track outcomes in your own practice and support the collective efforts to demonstrate effectiveness and value.
  • Identify and set up a quiet and professional space. Notice what your patients/clients will see.
  • Consider employing multiple monitors to accommodate client visibility as well as documentation requirements.
  • Study tips for effective telehealth sessions.
  • Ensure you are still properly documenting visits as you normally would with an in-person visit.
  • Identify teaching aides (labels, food/product photos) for telehealth purposes.
  • Determine how information (e.g. action plan, recommendations, written educational materials) will be provided to the client (e.g., email, provider portal, website) if not using a telehealth platform that enables document sharing.
  • Consider employing multiple monitors to accommodate client visibility as well as documentation requirements.
  • Ensure you are still properly documenting visits as you normally would with an in-person visit.

Coding Billing and Payment: MNT/DSMT Delivered via Telehealth

  • MNT provided via telehealth is still MNT. The CPT® codes used to submit claims to Medicare (most private payers and Medicaid) for in-person visits are the same codes used for telehealth: 97802, 97803, 97804, G0270. Watch this video about CPT® and G codes for RDNs.
  • CMS1500 Claims: During the COVID-19 emergency, you do not need to use Place of Service code 02 - Telehealth when submitting claims to Medicare. Continue to use the same Place of Service code you would use if the service had been provided in-person. Modifier 95 should be applied to claim lines that describe services furnished via telehealth, regardless of whether the MNT or DSMT was provide using approved audio-visual technology or audio-only communication (telephone).
  • Outpatient (hospital) – UB-04 Form: On April 30, 2020 CMS announced that MNT and DSMT can be provided in the hospital outpatient setting (Provider-Based Departments) remotely to a patient in their home, effective for services rendered March 1, 2020. Services should be billed the same as if they were provided in-person. Patients must be registered as hospital outpatients. RDNs can seek further direction from and collaborate with compliance/regulatory and billing staff at their hospitals. For more information, read the CMS Guidance.
  • Get clarification from private payers and state Medicaid programs for how to submit claims for MNT provided via telehealth.
    • Place of service code, if other than (02), and/or
    • Use of any modifiers. For example, modifier 95 describes synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system.
  • Rural Health Centers (RHCs): When RDNs in RHCs provide MNT via telehealth to Medicare beneficiaries, the RHC will be paid $92.03 for the telehealth interaction. The All-Inclusive Rate (AIR) will be paid, but these claims will automatically be reprocessed in July with the new payment rate.
    • Use the HCPCS code G2025 with modifier "CG" on the claim for services furnished via telehealth through June 30, 2020. After July 1, 2020, the CG modifier does not need to be used.
    • The home became an eligible originating site on March 6, 2020.
    • For more information read the CMS guidance.
    • Confirm policies for Medicaid and private payers.
  • Federally Qualified Health Centers (FQHCs): When RDNs in FQHCs provide MNT via telehealth to Medicare beneficiaries, the FQHC will be paid$92.03 for the telehealth interaction. The Prospective Payment System (PPS) rate will be paid, but these claims will automatically be reprocessed in July with the new payment rate
    • Claims should include the following information:
      • Provide the respective PPS specific payment system codes (GO466, G0467), and
      • The HCPCS/CPT code that describes the services furnished via telehealth (e.g., MNT; 97802, 97803, G0270, or DSMT G0108) with modifier 95; and
      • HCPCS G2025 with modifier 95
    • Beginning July 1, 2020, FQHCs will only be required to submit G2025 where modifier 95 may be appended but is not required.
    • The home became an eligible originating site on March 6, 2020
    • For more information read the CMS guidance.
    • Confirm policies for Medicaid and private payers.
  • Online digital assessment and management services codes (98970, 98971, 98972) for which RDNs may be reimbursed by private payers for electronic communication with established patients. In the Medicare Physician Fee Schedule CY21 Final Rule, CMS noted RDNs are not eligible to bill for these codes for Medicare patients. Examples of use with non-Medicare patients:
    • 98970 A 70-year-old male with insulin dependent diabetes submits an online query through his registered dietitian nutritionist's (RDN) EHR portal reporting nausea and vomiting due to the flu and seeking guidance on diabetes self-management.
    • 98971 A 65-year-old male with congestive heart failure submits an online query through HIPAA-compliant encrypted email to his RDN regarding a recent 7-lb weight gain.
    • 98972 A 40-year-old female with newly diagnosed type 2 diabetes submits an online query through her registered dietitian nutritionist's EHR portal after noticing her morning fasting blood glucose levels were gradually increasing.
  • Parity:
    • Medicare pays for MNT provided via telehealth at the same rate as in-person visits. See the Medicare physician fee schedule for more information. The Coronavirus Aid, Relief and Economic Security (CARES) Act increases payments to RDNs and other Medicare providers by two percent by temporarily suspending sequestration. Clarify rates with private payers and Medicaid as they may or may not pay for telehealth services at the same rate as an in-person encounter.
    • For more information on state payment parity laws, refer to the Center for Connected Health Policy.
  • Certified providers of accredited Diabetes Self-Management and Training programs can provide DSMT and submit claims to Medicare using codes G0108 and G0109. Services can be provided by any provider type under the accredited and recognized DSMT program (RDNs, RNs, pharmacists, etc.). Programs contracted with private payers and Medicaid programs should seek clarification regarding telehealth policies.
  • RDNs providing MNT to Medicare Advantage (Medicare Part C) enrollees should contact Medicare Part C plans directly as CMS has issued guidance allowing these plans to provide enrollees access to Medicare Part B services via telehealth in any geographic area and from a variety of places, including beneficiaries' homes.
  • Private/commercial payers:

Key questions to ask private payers and Medicaid about billing for services provided via telehealth (Make sure to contact provider services and not customer service):

  • Is the fee schedule for MNT delivered using telehealth the same as in-person visits?
  • What place of service code should I use?
  • Is a modifier required? If so, which modifier?
  • What communications technologies are allowed?

Can services be provided telephonically? (e.g., if client does not have access to technology or internet).

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