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COVID-19 Reimbursement

April 30, 2020 Update: Communication Technology-Based Services During the COVID-19 Pandemic

On April 7, 2020, we posted the telehealth payment requirements that have been waived during the COVID-19 pandemic. On April 30 we updated the telehealth requirements. These waivers have significantly assisted wound/ulcer professionals to continue providing assessments and management via two-way audio-visual technology. Some wound/ulcer management professionals have reported that a segment of their patients does not have access to the required telehealth technology or does not feel comfortable using it. Yet those patients still need their wounds/ulcers assessed and managed by their physician or qualified healthcare professional (QHP), but do not feel safe to leave their homes at this time. This author explains some communication technology-based services (CTBS) that wound/ulcer management professionals can provide if telehealth is not a viable option.

Information regarding coding, coverage, and payment is provided as a service to our readers. Every effort has been made to ensure accuracy. However, HMP and the author do not represent, guarantee, or warranty that coding, coverage, and payment information is error-free and/or that payment will be received.

Over the past few years, the American Medical Association (AMA) and the Centers for Medicare & Medicaid Services (CMS) have created codes and regulations for health care professionals to provide CTBS to their patients. Most wound/ulcer management professionals have not incorporated these services into their practices but may find them to be very useful during the COVID-19 pandemic. The March 31, 2020 interim final rule, entitled Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency (PHE), relaxed some of the CTBS regulations retroactive to March 1, 2020. On April 30, 2020, the CMS further relaxed some of the CTBS regulations retroactive to March 1, 2020.

I prepared a table (download pdf HERE) showing a comparison of the 2020 CTBS regulations vs. the temporary COVID-19 CTBS waivers as we know them on April 30, 2020. Keep in mind that the waivers are temporary during the PHE.

Document these CTBS services as you would document an in-person visit. In addition, state that the service was provided via telemedicine and include:

·      Patient location

·      Provider location

·      Names of all persons participating in the telemedicine service and their role in the encounter

·      Start and stop time

·      Total time

·      Discussion details

·      Beneficiary response

Should additional CTBS waivers be released, I will update the table and will inform readers when updates are posted.

Stay safe and stay healthy!

Kathleen D. Schaum oversees her own consulting business and is a founding member of the Today’s Wound Clinic editorial advisory board. She can be reached for consultation and questions at

For related articles, see:


Telehealth Waivers During COVID-19 Public Health Emergency” at


"ICD-10-CM Coding Guidelines for COVID-19" at .

COVID-19 Reimbursement
Kathleen D. Schaum, MS
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