Telehealth and Risk Adjustment Validation

Richmond , VA
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Debating the interpretation of the CMS telehealth video requirement to validate HCC conditions.
This (quote below), to my knowledge, has been interpreted as the video needing to be enabled for the entirety of the visit.
Thoughts? Do we have guidance or update anywhere that delineates between video use for partial vs full viisit? (i.e. if the visit is started as audio/visual, but the video drops, can that still be used to validate risk adjustment purposes?

RE: 'Diagnoses resulting from telehealth services can meet the risk adjustment face-to-face requirement when the services are provided using an interactive audio and video telecommunications system that permits real-time interactive communication.' [CMS: Applicability of diagnoses from telehealth services for risk adjustment ]
I was about to say that HCCs could NOT be captured with a telephone visit, but - per CMS: (this document was updated in April 2022)

"Question: In light of the COVID-19 pandemic, can HHS clarify which telephone service codes are valid for data submissions for the HHS-operated risk adjustment program? Response: Recognizing the continuing increased need for providing telephone and virtual services during the COVID-19 public health emergency, HHS gave additional consideration to the treatment of telephone-only services in the HHS-operated risk adjustment program and announced additional codes for 2020 and 2021 benefit year data submissions for the HHSoperated risk adjustment program. HHS is now announcing the extension of this policy to the 2022 benefit year data submissions for the HHS-operated risk adjustment program. [emphasis added by me]

HHS will therefore designate diagnosis codes from telephone-only service CPT codes (98966- 98968, 99441-99443) as valid for risk adjustment diagnosis filtering purposes in risk adjustment data submissions for the 2020, 2021, and 2022 benefit years for the HHS-operated program, subject to applicable state law requirements. Like telehealth visits, telephone-only services are subject to the same requirements regarding provider type and diagnostic value and must be reimbursable under applicable state law. We recognize that many conditions cannot be diagnosed telephonically but will defer to applicable coding and diagnosis guidelines setting groups (e.g., American Medical Association) on what a permissible diagnosis telephonically may be.7 Risk adjustment eligible diagnosis codes provided via allowable telehealth and telephone-only services will be validated in HHS-operated risk adjustment data validation in the same manner as risk adjustment diagnosis codes provided via in-person services are validated. We also intend to reconsider these codes’ inclusion for future benefit years, as appropriate."

this was a reminder to update the information in my head on a regular basis, which is something I try to do.