During COVID-19 public health emergency (COVID-19 PHE), CMS expanded the scope of telehealth/ telemedicine services. In this blog, we shared telehealth billing guidelines that are applicable only for Gastroenterologists. CMS increased payment for telephone evaluation and management codes 99441-99443 to the level of office/outpatient E/M codes 99212-99214. These telehealth rules were expanded to all Medicare beneficiaries and included originating sites physician offices, skilled nursing facilities, and hospitals.
These rules allowed two-way, real-time audio/visual telehealth services to be paid under the Medicare Physician Fee Schedule at the same amount as in-person services for new as well as existing patients. Hospitals and a range of clinicians, including doctors, nurse practitioners, clinical psychologists, nutrition professionals, and licensed social workers can provide telehealth.
Medicare will allow audio-only telephone E/M visits to be reported as telehealth, but they must be reported with the telephone E/M codes 99441-99443. Only two-way, real-time audio/visual E/M visits can be reported using codes 99201-99215. In addition to traditional telehealth platforms, during the PHE CMS will allow apps like FaceTime and Skype as acceptable platforms.
Please note that on July 19, 2021, the public health emergency was renewed for 90 days, expiring on Oct 18, 2021, which also includes the extension of the 1135 federal blanket waivers issued by CMS.
Telehealth Billing Guidelines
- Effective retroactively from March 1, 2020, national level payment for telephone (audio-only) E/M codes 99441-99443 will increase from $15, $31 and $39 respectively to $46, $56 and $110 to match office/outpatient E/M code payments for 99212-99214.
- You must report 99441-99443 with modifier 95 and place of service (POS) where the visit would have taken place in person prior to the public health emergency (e.g., 11-Office, 22-Hospital Outpatient, 23-ASC) in order to get the higher rates. Claims without modifier 95 will be paid at lower rates.
- E/M level selection for telehealth (real-time audio/visual) can be based on medical decision making or time and CMS has temporarily removed any requirements regarding documentation of medical history and/or physical exam in the medical record during the COVID-19 crisis.
- Most telehealth services can be provided to both new and established patients, including 99201-99215 and 99441-99443.
- Clinicians can provide remote patient monitoring services to patients with acute and chronic conditions and can be provided for patients with only one disease.
- Physicians can supervise their clinical staff using virtual technologies when appropriate, instead of requiring in-person presence.
Medicare telehealth services include office visits and consultations, among other services, provided by an eligible provider using an interactive two-way telecommunications system with real-time audio and video or audio-only telephone. Clinicians can report telehealth visits for both new and established patients on any real-time, non-public communication platforms, such as FaceTime and Skype, and sets payment the same as in-person E/M visits during the COVID-19 PHE.
E/M level selection can be based on medical decision making (MDM) or typical time listed in the CPT code description and CMS has temporarily removed any requirements regarding documentation of medical history and/or physical exam in the medical record during the COVID-19 crisis.
Select the appropriate code (99201-99215) and use the place of service (POS) that would have been reported had the service been furnished in person (e.g., 11-Office, 22-Hospital Outpatient, 23-Ambulatory Surgery Center). This will allow Medicare to pay for the service at the same rate that would have been paid if the service was furnished in person based on the provider’s location (i.e., facility or non-facility).
Providers must also append telehealth modifier 95 to claim lines to identify that the service was furnished via telehealth. Providers who continue to use the general telehealth POS 02 code will be paid at the ‘facility’ rate.
Telephone Evaluation and Management Service
CPT codes to describe telephone E/M are time-based. Effective March 1, 2020, payment for telephone E/M code 99441-99443 is equivalent to 99212-99214 and can be used for the new or established patients during the PHE. Use modifier 95 and place of service (POS) where the visit would have taken place in person prior to the public health emergency (e.g., 11-Office, 22-Hospital Outpatient, 23-ASC). Check if your commercial payers pay for these services before reporting the codes for non-Medicare beneficiaries.
e-Consultations are interprofessional telephone, internet, or EHR provider-to-provider consultations. Code selection is time-based.
- CPT Code 99446 – Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician, including a verbal and written report to the patient’s treating/requesting physician or other qualified health care professional; 5-10 minutes of medical consultative discussion and review ($18)
- CPT Code 99447 – 11-20 minutes of medical consultative discussion and review ($37)
- CPT Code 99448 – 21-30 minutes of medical consultative discussion and review ($56)
- CPT Code 99449 – 31 minutes or more of medical consultative discussion and review ($74)
- CPT Code 99451 – Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician, including a written report to the patient’s treating/requesting physician or other qualified health care professional, 5 minutes or more of medical consultative time ($37)
- CPT Code 99452 – Interprofessional telephone/Internet/electronic health record referral service(s) provided by a treating/requesting physician or other qualified health care professional, 30 minutes ($37)
As mentioned earlier we shared telehealth billing guidelines that are applicable for Gastroenterologists. For detailed telehealth guidelines for your practice, you can refer to your commercial payer billing resources. Medical Billers and Coders (MBC) is a medical billing company that provides medical billing and coding services for various medical specialties. For Gastroenterology billing and coding services, contact us at firstname.lastname@example.org/ 888-357-3226.