Signature Requirements for Telehealth Medicare Billings.

General practitioners (GPs) and practice managers across Australia have been grappling with a significant concern – the signature requirements for Telehealth Medicare billings. In a rapidly evolving healthcare landscape, where telemedicine has become a pivotal tool for patient care, the issue of collecting signatures for telephone consultations has emerged as a challenge.

The Challenge

One of the primary concerns that surfaced is the absence of a standardized mechanism for collecting patient signatures during telephone consultations. Telephone consultations pose a unique challenge, unlike in-person visits where a physical signature or electronic consent is more straightforward. The most straightforward recommendation to collect signatures was via email, but not all patients have access to or use email regularly. This apparent gap in the system prompted a much-needed review of the existing requirements for signatures, particularly in the context of Medicare billings, including Telehealth services.

The Blanket Rule

The fundamental rule in Medicare billings is clear: a patient must provide their signature or engage in a similar action to assign the Medicare benefit to their doctor. This could be in the form of a written signature, the press of a button on an electronic device, or through email consent. However, the question arises: what if none of these options are feasible?

Exemptions

Fortunately, there are exemptions in place to address such scenarios. For Telehealth consultations, the applicable exemption is when the “patient is unable to sign” and “verbal consent obtained.” However, a common misconception arises here – many GPs assume that simply noting these exemptions in the clinical records would suffice. Unfortunately, this is incorrect.

Proper Documentation

To ensure compliance, the notations “patient is unable to sign” and “verbal consent obtained” must be accurately entered in the designated sections of the billing form on the practice’s software. Virtually all practice software includes the “Patient unable to sign” and the “Practitioner’s Use” sections. Properly documenting these exceptions is crucial to avoid complications down the line.

A Practical Reminder

While these exemptions provide flexibility, GPs should exercise caution. It’s essential to use the “patient is unable to sign” and “verbal consent obtained” notations only when other methods of consent are genuinely unavailable. Overusing these exemptions may inadvertently draw the attention of Medicare investigators. Although no wrongdoing may be identified, the experience could prove unpleasant.

Final Note

It’s important to emphasize that this article does not constitute legal advice.

References:

Bulk billing a telehealth video consultation. Services Australia. 

https://www.servicesaustralia.gov.au/bulk-billing-telehealth-video-consultation?context=23366 Last accessed: 07.10.2023.

Assignment of benefit. Services Australia. https://www.servicesaustralia.gov.au/assignment-benefit-signature-requirements-and-exemptions?context=23366 Last accessed: 07.10.2023.


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