Coding for telemedicine
Many payers, including Medicare, provide coverage for telehealth services. Telehealth is typically defined as real-time audio and visual communication with a patient, usually via a telehealth portal or platform. During the COVID-19 emergency, Medicare and many states have waived certain coverage requirements; check with your state medical association for details.
Coding for telemedicine services varies among carriers and Medicare. We suggest you obtain verification of benefits on telemedicine just like any other service; a verification sheet may be helpful. Unfortunately, coverage also varies from policy to policy, so one Blue Cross policy may cover telemedicine, and another will not.
NEW from Medicare
- Phone Calls: Medicare will now pay for phone calls (audio-only) using existing CPT Codes 99441-443 (for clinicians) and 98966-68 for clinical staff. The code selection is based on time. Reimbursement ranges from about $14 to $41.
- Non-Facility Rate for Telehealth E/M: Medicare will pay the higher non-facility rate for E/M telehealth visits during the public health emergency (PHE); and all telehealth services, not just those related to COVID-19. This policy is retroactive to March 1, 2020. As a result, physician claims should use the place of service code that would apply if the services were provided in person (POS 11 for a physician office) and should not use POS 2. They should use modifier 95 to indicate the service was provided via telehealth.
- Supervision of Incident-to Services: The direct supervision (i.e., on-site) requirement for Medicare incident-to services and for certain diagnostic tests can be performed via audio/visual real time communications technology.
- Evaluation and Management Coding: When billing for an E/M service provided via telehealth, you should use the same CPT Code you would use if the service were provided in person, but with one exception: Medicare will now allow telehealth visits to be coded based on complexity of medical decision-making or time, regardless of whether counselling and coordination of care comprise 50% of the visit. This is similar to the policy that will be in place in 2021 for all services, although currently it only applies to outpatient visits furnished via telehealth during the public health emergency. CMS also waived its rule allowing care for established and new patients.
- Expansion of covered telehealth services: CMS is allowing physicians to reduce or waive cost sharing for telehealth visits. It will also allow physicians licensed in one state to provide services to Medicare beneficiaries in another state. State licensure laws still apply. CMS has also added coverage for a series of new CPT Codes that can be furnished via telehealth. The codes and an in-depth discussion of the codes, their criteria and CMS reasoning are available in the interim final rule.
- CMS is not requiring the CR modifier on telehealth services. However, consistent with current rules for telehealth services, there are two scenarios where modifiers are required on Medicare telehealth professional claims:
- Furnished as part of a federal telemedicine demonstration project in Alaska and Hawaii using asynchronous (store and forward) technology - use GQ modifier.
- Furnished for diagnosis and treatment of an acute stroke - use G0 modifier.
ICD-10 codes should be related to the reason for the call or online interaction.
The AMA has developed a series of coding scenarios on telehealth you may find helpful. The revised version has a red box in the upper right corner stating: Updated April 3, 2020.
A billing company has put together a helpful list of telemedicine covered services, cost sharing, place of service (POS) and modifier requirements for state and national carriers on a google worksheet that is being updated daily. You can find it here: Telemedicine Billing Guidelines
NOTE: Review the source documents provided in the links to confirm the information is correct; this information is constantly changing.
Telehealth modalities and cost sharing
For the duration of the public health emergency, interactive telecommunications system means multimedia communications equipment that includes, at a minimum, audio and/or audio-video equipment permitting two-way, real-time interactive communication between the patient and distant site physician or practitioner.
In addition, the HHS Office for Civil Rights (OCR) is exercising enforcement discretion and waiving penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communication technologies, such as FaceTime or Skype, during the PHE for the COVID-19 pandemic.
Depending on the state, there may be parity laws where insurance companies are required to pay telemedicine at the same rate as an in-office visit.
There are also a number of other technology-based communication services short of a telehealth encounter that provide opportunities for patients to confer with and get advice from their physician.
- Digital e-visits – patient initiated through secure patient portal. These are typically electronic (or secure email) services.
- Physicians can bill using CPT Codes 99421-99423.
- If the communication is performed by clinical staff (e.g., an RN), Medicare requires the use of G codes G2061-G2063; third-party payers use 98970-98972.
- Evaluation of a recorded image or video – sent by a patient for evaluation and billed using G2010.
- Virtual check-in services – made via telephone or other digital communication and can be billed using G2012.
Coding for telehealth continues to change; check the College’s COVID-19 Resource Page regularly for updates. The Advocacy Council – we have you covered.