Yes. There are two ways around that right now.
The first way is to perform the monthly update using telemedicine. There is no requirement that this evaluation must be performed via a face-to-face visit. On March 17, CMS announced that CPT 99201-99215 can be submitted when providing these services remotely throughout the duration of the public health emergency. If all of the requirements in that announcement are met, the physician must provide the clinical information that demonstrates the necessity which can be accomplished using video/pictures.
The second way is completing the standard monthly eval “unless there is documentation which justifies why an evaluation could not be done within this timeframe.” If a patient needs surgical dressings during a public health emergency but this evaluation is not possible, given this guidance, it can be excluded if there is documentation explaining why. The doctor could document:
“Monthly eval was not performed due to the Public Health Emergency Declaration in response to the COVID-19 crisis. The risks and benefits of performing this eval were weighed, and in this case, under current CDC guidelines, the potential risks of having a face-to-face encounter with this patient outweighed the potential benefits. Therefore, a monthly eval of the wound was not performed. I feel comfortable ordering additional supplies in the absence of evaluating their wound given the circumstances.”
The corresponding policy article passage reads:
Clinical information, which demonstrates that the reasonable and necessary requirements in the policy regarding the type and quantity of surgical dressings provided, must be present in the beneficiary’s medical records. This information must be updated by the treating practitioner (or their designee) on a monthly basis. This evaluation of the beneficiary’s wounds(s) is required unless there is documentation in the medical record which justifies why an evaluation could not be done within this timeframe and what other monitoring methods were used to evaluate the beneficiary’s need for ongoing use of dressings.