The Centers for Medicare & Medicaid Services (CMS) lifted Medicare restrictions on the use of telehealth services during the COVID-19 emergency.
Key changes include:
· Effective March 6, 2020 and throughout the national public health emergency, Medicare will pay physicians for telehealth services at the same rate as in-person visits for all diagnoses, not just services related to COVID-19.
· Patients can receive telehealth services in all areas of the country and in all settings, including at their home.
· CMS will not enforce a requirement that patients have an established relationship with the physician providing telehealth.
· Physicians can reduce or waive cost-sharing for telehealth visits.
· Physicians licensed in one state can provide services to Medicare beneficiaries in another state. State licensure laws still apply
Scenario 1:
Patient comes to office for E/M visit, is tested for COVID-19 during the visit
Action
|
In-office E/M visit
|
Patient swab sample collected
|
COVID-19 test performed
|
Who is performing |
Physician/QHP |
Clinical staff (e.g., RN/LPN/MA) |
Laboratory |
Applicable CPT Codes |
99201-99205 (New Patient) |
Included in E/M |
87635: Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique |
Applicable ICD-10 codes |
Possible exposure to COVID-19 Z03.818 |
|
|
Place of Service (POS) |
11 Physician Office |
|
11 Physician office |
Scenario 2:
Patient comes to office for E/M visit re: COVID-19 and is directed to a testing site
Action
|
In-office E/M visit
|
Patient swab sample collected
|
COVID-19 test performed
|
Who is performing |
Physician/QHP |
Testing Site |
Laboratory |
Applicable CPT Codes |
99201-99205 (New Patient) |
99001: Handling and/or conveyance of specimen for transfer from the patient in other than an office to a laboratory (distance may be indicated) |
87635: Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique |
Applicable ICD-10 codes |
Possible exposure to COVID-19 Z03.818 |
|
|
Place of Service (POS) |
11 Physician Office |
15 Mobile Unit |
11 Physician office |
Scenario 3:
Patient received telehealth visit re: COVID-19, and is directed to come to physician office or physician’s group practice site for testing
Action
|
Patient evaluated for COVID-19 testing need: E/M telehealth OR
|
Pt goes to office
|
Throat swabs taken in office
|
COVID-19 test performed
|
Who is performing |
Physician/QHP |
|
Clinical Staff (e.g., RN/LPN/MA) |
Laboratory team |
Applicable CPT Codes |
New Patient: E/M Telehealth: 99201/99202/99203/99204/99205
99441 (5-10 min)
99442 (11-20 min)
99443 (21-30 min) |
Patient directed to proceed to office for COVID-19 testing |
99211 |
87635: Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique |
Applicable ICD-10 codes |
Possible exposure to COVID-19 Z03.818 |
|
|
|
Place of Service (POS) |
02 Telehealth |
|
11 Physician Office |
11 Physician office |
Note: Payers may require the use of Modifier 95 for telehealth services and add modifier 25 if same date of service as Physician/QHP assessment.
Scenario 4:
Patient received telehealth visit re: COVID-19, and is directed to unaffiliated testing site
Action
|
Patient evaluated for COVID-19 testing need: E/M telehealth OR
|
Pt goes to testing site
|
Throat swabs taken at remote testing site, delivered to lab
|
Coronavirus test performed
|
Who is performing |
Physician/QHP |
|
Testing Site |
Laboratory team |
Applicable CPT Codes |
New Patient: E/M Telehealth: 99201/99202/99203/99204/99205
99441 (5-10 min)
99442 (11-20 min)
99443 (21-30 min) |
99001: Handling and/or conveyance of specimen for transfer from the patient in other than an office to a laboratory (distance may be indicated) |
87635: Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique |
|
Applicable ICD-10 codes |
Possible exposure to COVID-19 Z03.818 |
N/A |
N/A |
|
Place of Service (POS) |
02 Telehealth |
15 Mobile Unit |
11 Physician office |
Note: Payers may require the use of Modifier 95 for telehealth services
Scenario 5:
Patient receives virtual check-in/online visit re: COVID-19 (not related to E/M visit), and is directed to come to physician office for testing
Action
|
Patient evaluated for COVID-19 testing need: Online digital E/M
|
Pt goes to office
|
Throat swab taken in office
|
COVID-19 test performed
|
Who is performing |
Physician/QHP |
|
Clinical Staff (e.g. RN/LPN/MA) |
Laboratory team |
Applicable CPT Codes |
New Patient: N/A |
Patient directed to proceed to office for COVID19 testing |
99211 |
87635: Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique |
Applicable ICD-10 codes |
Possible exposure to COVID-19 Z03.818 |
|
|
|
Place of Service (POS) |
11 Physician Office |
|
11 Physician Office |
11 Physician office |
Note: Add modifier 25 if same date of service as Physician/QHP assessment.
Scenario 6:
Patient receives virtual check-in/online visit re: COVID-19 (not related to E/M visit) and is directed to unaffiliated testing site
Action
|
Patient evaluated for COVID-19 testing need: Online digital E/M
|
Pt goes to testing site
|
Throat swab taken at testing site, delivered to lab
|
COVID-19 test performed
|
Who is performing |
Physician/QHP |
|
Testing Site |
Laboratory team |
Applicable CPT Codes |
New Patient: N/A |
|
99001: Handling and/or conveyance of specimen for transfer from the patient in other than an office to a laboratory (distance may be indicated) |
87635: Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique |
Applicable ICD-10 codes |
Possible exposure to COVID-19 Z03.818 |
|
|
|
Place of Service (POS) |
11 Physician Office |
|
15 Mobile Unit |
11 Physician office |
Scenario 7:
Telehealth visit for a COVID-19 diagnosed patient
Action
|
Communication method
|
Patient assessed: E/M telehealth, telephone assessment (Flexibility: permit audio only for E/M telehealth)
|
Who is performing |
|
Physician/QHP |
Applicable CPT Codes |
Audio or Audio/Video |
New Patient: E/M Telehealth: |
Applicable ICD-10 codes |
|
U07.1, COVID-19 |
Place of Service (POS) |
|
02 Telehealth |
Note: Payers may require the use of Modifier 95 for telehealth services.
Scenario 8:
Patient with COVID-19 receives virtual check-in OR on-line visits via patient portal/e-mail (not related to E/M visit) OR telephone call from qualified nonphysician (those who may not report E/M)
Action
|
Communication method
|
Patient evaluated
|
|
Who is performing |
|
Physician / QHP |
Qualified non-physician (may not report E/M) |
Applicable CPT Codes |
Virtual Check-In Other Phone Call |
G2010 Remote Image |
98966 (5-10 min) |
|
Online Visits |
99421 (5-10 min) |
98970/G2061 (5-10 min) |
Applicable ICD-10 codes |
|
U07.1, COVID-19 |
|
Place of Service (POS) |
|
11 Physician Office or other applicable site of the practitioner’s normal office location |
11 Physician Office or other applicable site of the practitioner’s normal office location |
Scenario 9:
Physician orders remote physiologic monitoring following patient quarantined at home after receiving COVID-19 diagnosis
Action |
Patient receives initial set-up of monitoring device and education on its use |
|
Remote physiologic monitoring treatment management services (First 20 minutes) |
Remote physiologic monitoring treatment management services (Each additional 20 minutes) |
Collection and interpretation of physiologic data digitally stored and/or transmitted by the patient to physician/QHP (Minimum of 30 minutes) |
|
Who is performing |
Physician/QHP/Clinical Staff |
|
Physician/QHP |
Physician/QHP |
|
Physician/QHP |
Applicable CPT Code(s) |
99453: Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education on use of equipment |
+ |
99457: Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; first 20 minutes |
99458: Remote physiologic monitoring treatment management services, clinical staff/physician/ other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; each additional 20 minutes (List separately in addition to code for primary procedure) |
OR |
99091: Collection and interpretation of physiologic data (e.g., ECG, blood pressure, glucose monitoring) digitally stored and/or transmitted by the patient and/or caregiver to the physician or other qualified health care professional, qualified by education, training, licensure/ regulation (when applicable) requiring a minimum of 30 minutes of time, each 30 days |
Place of Service |
11 Physician Office |
|
11 Physician Office |
11 Physician Office |
|
11 Physician Office |
Notes |
Do not report 99453 for monitoring of less than 16 day |
|
Bill once per calendar month, regardless of number of parameters monitored |
Use 99458 in conjunction with 99457 |
|
Bill once per 30 days |
Scenario 10:
(Non-COVID-19 case) Telehealth visit for a non-COVID-19 patient
Action
|
Communication method
|
Patient assessed: E/M telehealth, telephone assessment (Flexibility: permit audio only for E/M telehealth)
|
Who is performing |
|
Physician/QHP |
Applicable CPT Codes |
Audio or Audio/Video |
New Patient: E/M Telehealth: |
Applicable ICD-10 codes |
|
Report relevant ICD-10 code(s) related to reason for call or online interaction |
Place of Service (POS) |
|
02 Telehealth |
Note: Payers may require the use of Modifier 95 for telehealth services.
Scenario 11:
(Non-COVID-19 case) Patient receives virtual check-in OR on-line visits via patient portal/e-mail (not related to E/M visit) OR telephone call from qualified nonphysician (those who may not report E/M)
Action
|
Communication method
|
Patient evaluated
|
|
Who is performing |
|
Physician / QHP |
Qualified non-physician (may not report E/M) |
Applicable CPT Codes |
Virtual Check-In Other Phone Call |
G2010 Remote Image |
98966 (5-10 min) |
|
Online Visits |
99421 (5-10 min) |
98970/G2061 (5-10 min) |
Applicable ICD-10 codes |
|
Report relevant ICD-10 code related to reason for call or online interaction |
|
Place of Service (POS) |
|
11 Physician Office or other applicable site of the practitioner’s normal office location |
11 Physician Office or other applicable site of the practitioner’s normal office location |
This COVID-19 resource from the Medical Billers and Coders (MBC) provides an up to date summary of telehealth rules, including state licensure and private payer policies regarding telehealth coverage. The federal government is requesting private payers to cover telehealth for COVID-19 as a way to minimize the spread of the virus in the community and clinical settings. Please note that changes in payer policies are changing from day to day, so be sure and check the policies of your practice’s most common payers.