Keeping up with the changes in coding for telehealth

Keeping up with the changes in coding for telehealth

The Advocacy Council regularly receives queries from members on how to correctly code specific scenarios. Recently we received the following two questions:

Q: COVID-19 brought about many changes that were developed quickly – it’s hard to keep up. What are the changes I need to know about telehealth?

A: Effective for the duration of the COVID-19 Public Health Emergency (PHE), Medicare has broadened the requirements for telehealth visits to include:

  • Patients may be either a new or an established patient.
  • If you are using time to bill for your telehealth visits, note that face-to-face times for a new patient are not the same as for an established patient.
  • Medicare will pay the higher non-facility rate for E/M telehealth visits during the PHE for 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.
  • A provision that telemedicine visits can provide the same services as would be provided during an in-person visit and will be paid at the same rate as in-person visits.
  • The patient may be located in any geographic location (not just those designated as rural), in any healthcare facility, or in their home.
  • CMS may also allow physicians licensed in one state to provide services to Medicare beneficiaries in another state. State licensure laws still apply. Please check for the telehealth laws for your state.
  • The Medicare coinsurance and deductible would generally apply to these services; however, the HHS Office of the Inspector General is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.
    • Common telehealth CPT and HCPCS codes include:
      • 99201-99215: Office or other outpatient visits
      • G0406-G0408: Follow-up inpatient telehealth consultations furnished to beneficiaries in hospitals or skilled nursing facilities (SNF)

Q: Does CMS allow telephone only visits to be billed using 99201-99205 and 99211-99215? Do private payers cover telephone only visits?

A: Medicare does not cover E/M codes (99201 – 99205 and 99211-99215) for telephone only visits. For Medicare to cover those codes, telehealth services must be furnished via both audio and visual communication.

For the duration of the PHE for the COVID-19 pandemic, Medicare will make separate payment for audio-only (telephone) visits described by CPT codes 98966-98968 (for clinician staff) and CPT codes 99441-99443 (clinicians) as outlined on page 125 in the Interim Final Rule. You can also use a virtual check-in code – G2012.

Other payers may allow use of the E/M codes for audio only. You would need to check with the payer.

ICD-10 codes should be related to the reason for the call or online interaction.

Check out our telehealth toolkit for more helpful resources.
Do you have a coding conundrum of your own? Share it with us!