In a bold move announced March 17, 2020, Medicare temporarily allowed clinicians to provide care to patients physically located somewhere else and communicating through electronic means. Starting with care provided since March 6, 2020, and continuing at least through the end of the COVID-19 Public Health Emergency (PHE), telehealth guidelines are being relaxed in an effort to reduce transmission risk and to conserve resources (both clinician time and physical equipment).
While Medicare has started to implement “virtual check-ins” through phone, video chat, and online patient portals for the last two years, this new expansion allows the full range of evaluation and management (E/M) care to be delivered at home or in senior care facilities without requiring the patient to put themselves at risk by going to a doctor’s office or hospital. The intention is to allow the at-risk Medicare population to receive routine care and follow-up (i.e., diabetes care, prescription refills) and initial screenings for possible contagious illnesses (including COVID-19) without having to access in-person care unless absolutely necessary.
What About Medicaid?
Determined on a State-by-State basis and supported by the Federal mandate, Medicaid already provides more latitude for telehealth services and is matching Medicare’s response throughout the PHE.
And Private/Commercial Insurance?
Starting with United Healthcare, private and commercial insurers are mirroring CMS guidelines and allowing telehealth services in full at least through the PHE. Both Aetna and BCBS network are waiving cost-sharing and copays for members’ telehealth services for in-network providers. While specifics are available on a company-by-company basis, most private and commercial carriers are supporting the telehealth format to physically distance patients and providers.
Coding and Billing Requirements for Telehealth Services
Telehealth E/M Billing
As of March 6, 2020, providers can bill new and established patients and their insurance payers for telehealth services for E/M, including the office visit codes 99201-00205 for new patients and 99211–99215 for established patients. At least for Medicare and Medicaid, these services will be paid at the current fee schedule, and patients will be responsible for associated copays and co-deductibles for non-COVID-19-related care, although the HHS Office of the Inspector General (OIG) is allowing flexibility for providers to reduce or waive cost-sharing regularly prohibited by federal healthcare programs.
For emergency room providers and initial inpatient contacts, use the following codes:
- G0425-G0427 – Telehealth consultations, emergency departments or initial inpatient
- G0406-G0409 – Follow-up inpatient telehealth consultations for hospitals or SNFs
Providers may bill for virtual check-in services furnished through various communication technologies, including telephone, computer, secure text messaging, and patient portal (HCPCS code G2012). In addition, separate from these virtual check-in services, captured videos or images can be sent to a physician (HCPCS code G2010). From CMS:
- HCPCS code G2012: Brief communication technology-based service, e.g., virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous seven days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.
- HCPCS code G2010: Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment.
Defined as communication between a patient and their provider through an online portal or email. Services may be billed using CPT codes 99421-99423 and HCPCS codes G2061-G2063, as applicable.
- 99421: Online digital evaluation and management service, for an established patient, for up to 7 days, the cumulative time during the 7 days; 5–10 minutes
- 99422: Online digital evaluation and management service, for an established patient, for up to 7 days cumulative time during the 7 days; 11– 20 minutes
- 99423: Online digital evaluation and management service, for an established patient, for up to 7 days, the cumulative time during the 7 days; 21 or more minutes
This care must be patient initiated. The patient can initiate a virtual check-in and the practice can let the patient know about their options. If the patient calls back within 7 days, then the time from the virtual check-in can be added to the digital E/M code and only the digital E/M code is billed. Cost sharing applies to the E/M service; copays are waived for COVID-19 testing, but deductibles may still apply.
- 99453: Remote monitoring of physiologic parameters (s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education on use of equipment.
- 99454: Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate) initial; device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days.
- 99457: Remote physiologic monitoring treatment management services, 20 minutes or more of clinical staff, physician, or other qualified health professional time in a calendar month requiring interactive communication with the patient/caregiver during the month.
Telephone Only (Audio Only)
- 99441: Telephone E/M service provided by a physician to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment, 5-10 of medical discussion.
- 99442: Telephone E/M service provided by a physician to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment, 11-20 of medical discussion.
- 99443: Telephone E/M service provided by a physician to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment, 11-20 of medical discussion.
CMS telehealth policy updates as of April 30, 2020:
- CMS is increasing payment for audio-only telephone E/M services (CPT codes 9944199443) such that they are paid at the same rate as similar office and outpatient E/M visits, resulting in increased payments from $14-$41 to $46-$110. CMS believes that the resources required to furnish these services during the PHE are better captured by RVUs associated with level 2-4 established office/outpatient E/M visits. CMS is not increasing payment for CPT codes 98966-98968, which are intended for practitioners that cannot separately bill for E/M. This policy is retroactive to March 1, 2020.
- For telehealth services other than CPT codes 9944199443 and 98966-98968 (now added to the list of covered telehealth services), Medicare continues to require modalities that have both audio and video capabilities.
- During the COVID-19 public health emergency, rural and site limitations are removed. Telehealth services can now be provided regardless of where the enrollee is located geographically and type of site, which allows the home to be an eligible originating site. However, locations that are newly eligible will not receive a facility fee.
- CMS is forgoing its typical rulemaking process to add new services to the list of Medicare services that may be furnished via telehealth. Instead, CMS will add new telehealth services on a sub-regulatory basis to speed up the process of adding codes to the list.
Charting and Documentation
Like documenting an in-person encounter, charting must support the claim with history, a review of systems, consultative notes or any information used to make a medical determination and plan, and care instructions. Additionally, consider it prudent to also include a statement that the service was provided through telehealth, including the location of both the patient and the provider and the names and roles of any other persons participating in the telehealth service.
As we move through the coming weeks and months in this unprecedented situation, it is our goal to keep you informed of business and operational issues, including billing and coding requirements, so that we may all see this through to completion intact.
Contact us if you find yourselves in need of third-party medical billing and coding support.