Medicare required providers to append special modifiers to their CPT and HCPCS codes when billing for telehealth services. The two primary modifiers for telehealth services were GT (indicating the service was delivered via an interactive audio and video telecommunications system) and GQ (indicating the service was delivered via an asynchronous telecommunications system).
Effective January 1, 2018, the use of modifier GT on professional claims has been eliminated. Use of the telehealth POS code 02 certifies that the service meets the telehealth requirements. This Change Request (CR) 10152 eliminates the requirement to use the GT modifier (via interactive audio and video telecommunications systems) on professional claims for telehealth services. Use of the telehealth Place of Service (POS) Code 02 certifies that the service meets the telehealth requirements.
Instead of using the GT modifier, providers must mark their telehealth services claims with ‘Place of Service (POS) 02.’ A POS code is required on professional claims for all services-telehealth or otherwise-and using POS 02 signals to Medicare that the service was provided via telehealth. Previously, providers were instructed to use the POS code for where the patient was located at the time of the service.
Effective January 1, 2018, POS 02 is to be used for all telehealth services under Medicare. The introduction of POS 02 rendered it unnecessary to also require the distant site practitioner report the GT modifier on the claim.
There are a couple specific situations where CMS still wants providers to use GT or GQ modifiers. Critical Access Hospitals (CAHs) billing for distant site practitioners under Method II must continue to use the GT modifier on institutional claims. This is because institutional claims do not use a POS code, so Medicare still needs a way to identify those services as telehealth. In addition, for those providers participating in the Alaska or Hawaii federal telemedicine demonstration programs, they must still use the GQ modifier to maintain the distinction between synchronous and asynchronous telehealth services.
Providers must keep in mind, however, that by billing claims with POS 02 (or with GT or GQ), the provider is certifying that both the broad and code-specific telehealth requirements have been met. This includes all the statutory requirements for telehealth service coverage under Medicare (e.g., rural area, originating site, interactive audio and video telecommunications system).
If a provider delivers a telehealth service while a Medicare patient is located at home, the service would not meet the Medicare statutory requirements and the provider should not append POS 02 (or GT or GQ) to that code. False or erroneous coding of claims can expose providers to audits, overpayments, and potential liability under the False Claims Act.
When billing professional claims for all telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE), bill with:
Synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system. Use of the 95 modifier indicates a real-time interaction between a physician or other qualified health care professional and a patient who is located at another site than his/her physician or other qualified health care professional or by him/herself. Modifier 95 may be appended to the services listed in Appendix P of the CPT Code Book or marked with a star in the code lists within the CPT Code Book.
Via asynchronous telecommunications system (e.g., 99201-GQ). Use of the GQ modifier certifies an asynchronous telecommunications system was used, such as Store and Forward technologies, to transmit medical or behavioral health information to the provider at the ‘distant site.’
Via interactive audio and video telecommunication systems (e.g., 99201-GT). Use of the GT modifier certifies the member was present at an eligible “originating site” when the telehealth/telemedicine service was performed. This modifier is used exclusively by the ‘distant site’ provider.
Telehealth services for diagnosis, evaluation or treatment of symptoms of an acute stroke. This modifier should be appended to both the originating and distant site provider services as clinically appropriate when billing for an acute stroke telehealth service. This modifier should be appended on services that were rendered or furnished in such sites as a hospital, critical access hospital or mobile stroke unit. Such services should also be billed with the appropriate POS code on professional claims to indicate telehealth service.
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