The government is relaxing guidelines to ensure seniors get the healthcare they need during this national emergency. The Centers for Medicare & Medicaid Services (CMS) announced in a March 17, 2020, press release that it will make a temporary change in its reimbursement policy for telehealth services. For dates of service (DOS) on or after March 6, 2020, CMS will reimburse physicians providing telehealth services to Medicare patients across the country, with fewer restrictions.
The purpose of the decision was to allow seniors to communicate with their doctors without having to travel to a healthcare facility so that they can limit the risk of exposure and the spread of this virus. But what does that mean for coding? To answer that question, here is a brief overview of the three different types of telehealth services, along with the codes that may come into play when Medicare patients reach out to your provider with their health questions and concerns.
Virtual Check-In
- These codes document brief communications between a patient and a provider to determine whether a patient’s condition requires further services, including a face-to-face or telehealth office evaluation and management (E/M) visit.
- Use 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 7 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 for real-time, synchronous telephone interactions.
- If the patient has sent video, images, or other kinds of data transmissions (such as information from a monitor) for your provider to evaluate, use 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.
- No modifiers are needed with these codes. Only established patients may receive these services. Only providers who can perform and bill E/M services may bill for virtual check-ins. Make sure your documentation includes medical necessity and verbal patient consent.
Telephone Check-Ins
- Telephone check-ins performed by qualified non-physician professionals (NPPs), such as physical or occupational therapists, clinical psychologists, or speech-language pathologists (who cannot perform and bill for E/M services) are described by CPT® codes 98966 Telephone assessment and management service provided by a qualified non-physician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion, 98967 (11-20 minutes of medical discussion), and 98968 (21-30 minutes of medical discussion)
- Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian 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 minutes of medical discussion, 99442 (11-20 minutes of medical discussion), and 99443 (21-30 minutes of medical discussion) are currently not listed among the telehealth codes listed in the Medicare 1135 waiver.
E-Visit
- The service describes patient-initiated communications through electronic health record (EHR) portals, secure email, or other digital applications.
- Use 99421 Online digital evaluation and management service, for an established patient, for up to 7 days, a cumulative time during the 7 days; 5-10 minutes, 99422 (11-20 minutes), or 99423 (21 or more minutes) according to time for providers who can perform and bill for E/M services.
- Use G2061 Qualified non-physician healthcare professional online assessment and management, for an established patient, for up to seven days, a cumulative time during the 7 days; 5-10 minutes, G2062 (11-20 minutes), or G2063 (21 or more minutes) according to time for NPPs who cannot perform and bill for E/M services.
- Only established patients may receive these services. No modifiers are needed with these codes. Make sure physician documentation includes patient consent.
Medicare Telehealth Visits
- Only established patients may receive these services. However, the Medicare 1135 waiver allows them to be used for new patients “for claims submitted during this public health emergency.
- Distant site practitioners who can furnish and get payment for covered telehealth services (subject to state law) can include physicians, nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologists, clinical social workers, registered dietitians, and nutrition professionals,” according to the Medicare Telemedicine Health Care Provider Fact Sheet. Make sure you read the individual code descriptor closely for other provider limitations.
- Examples of common services that can be furnished via telehealth include 99201-99215 Office or another outpatient visit for the evaluation and management of a new/established patient, G0425-G0428 Telehealth consultation, emergency department or initial inpatient and G0406-G0408 Follow-up inpatient consultation communicating with the patient via telehealth according to the Medicare Telemedicine Health Care Provider Fact Sheet.
- Telehealth visits for Medicare patients, per CMS telehealth guidelines, require that you append place of service (POS) code 02 Telehealth to indicate the location where health services and health-related services are provided or received, through telecommunication technology.
- In addition, depending on the way the service was furnished, you would append modifier GQ Via asynchronous telecommunication system for services provided by store-and-forward technology. Distant site practitioners billing telehealth services under the critical access hospital (CAH) Optional Payment Method II must submit institutional claims using the modifier GT.
