Wiki Telehealth

As far as I know Aetna is the only one that will cover the 99441-99443/98966-98968 codes. They all want some sort of video capable phone. UHC is following medicare guidelines where you use a smart phone or video capable phone for office visits and use regular em codes with pos 2 and GT modifier for medicare and 95 modifier for commercial. virtual check ins I think need a photo or prerecorded video from the patient to qualify.
UHC does not want any modifier and neither does medicare. Regular e/m codes with 02 place of service. Horizon, Aetna, AmeriHealth all want GT or 95 modifiers along with place of service 02.
 
I read somewhere - and am trying to find the reference again - that the physician needs to review history, medication reconciliation, etc. while on the video portion of the call with the patient. Has anyone else seen this?
 
I found this today on the AMA website.
https://www.ama-assn.org/practice-management/digital/ama-quick-guide-telemedicine-practice

It looks like the restriction that telephone encounters are not able to be billed as E/M has been lifted temporarily-which is amazing. (I found that information first on the United Healthcare website from the UHC link at the bottom of this page.) But I found this particular link very helpful with the visual aids!

https://www.ama-assn.org/system/files/2020-03/covid-19-coding-advice.pdf

Hope this is helpful for everyone.
Thank you
 
I found this today on the AMA website.
https://www.ama-assn.org/practice-management/digital/ama-quick-guide-telemedicine-practice

It looks like the restriction that telephone encounters are not able to be billed as E/M has been lifted temporarily-which is amazing. (I found that information first on the United Healthcare website from the UHC link at the bottom of this page.) But I found this particular link very helpful with the visual aids!

https://www.ama-assn.org/system/files/2020-03/covid-19-coding-advice.pdf

Hope this is helpful for everyone.
The AMA coding advice seems to state audio/video or audio only. I will note that it is a little confusing as 99441-99443 are also listed in another column. And there's a statement of "(Flexibility: Permit audio only for E/M telehealth)." Flexibility by who??
The CMS advice clearly states otherwise. I have not seen any commercial insurance guidance that permits E/M when telephone only (I have seen policies stating telephone to be billed with G2012 or 99441-99443, depending on carrier). In our practice, we will only be billing telehealth for audio and video unless CMS provides other guidance.
https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf See Question 8. Specifies AUDIO/VIDEO.
 
Will you provide further insight into what you are documenting for location?
We are documenting something along the lines of:
Services provided via telehealth (Skype) after written consent from the patient on DATE at TIME via non HIPAA platform. Patient was located at residence. Provider was located in (town) office.
or
Services provided via telehealth (Skype) after verbal consent from the patient on DATE at TIME by EMPLOYEE via non HIPAA platform. Patient was located at daughter's residence in (town, state). Provider was located in his own residence.
I have not seen any requirement for the exact location. NGS Medicare had a webinar this past Wednesday and the question was posed about provider's location. It was stated the provider may be at his own home, and did not need to specify the address of his personal residence. Somewhere along the road, I heard that if the patient is NOT in the same state where your office is, you should specify that. Typically, you cannot provide services to a patient located in a state where physician is not licensed, but it was permitted during the emergency.
 
Thank you, csperoni! I truly appreciate how much information you have provided regarding telehealth across the forum(y)
 
MOST of the organ systems cannot just be examined visually. You could maybe get constitutional, psych, possibly limited skin. Via video only, you cannot examine eyes, ENT, respiratory, cardiovascular, GI, GU, lymphatic, musculoskeletal or neurologic. To the limited extent that an exam via video only is possible, you can count those if the documentation meets the requirements of 1995 or 1997.
In our practice, I have advised the providers that we will code based on time since basically 100% of time is counseling.
If coding based on time, I was reading that I can bill 99213 based on 15 minutes. Is that correct? Thanks!
 
I don't know if this is addressed in any of the official CMS guidance, but this exact question was posed during NGS Medicare telehealth webinar yesterday afternoon. The provider may be at home, or another location. Still bill POS 02.
If the provider is at home during the phone call/telehealth visit with patient, what do we use for Appointment Facility on our claims? This is not the same as POS. If we have multiple office locations do I just pick one at random to use for Appointment Facility?
 
If the provider is at home during the phone call/telehealth visit with patient, what do we use for Appointment Facility on our claims? This is not the same as POS. If we have multiple office locations do I just pick one at random to use for Appointment Facility?
NGS Medicare (webinar 3/25/20) did offer the guidance of putting the office location on the claim, and the provider may be at home. If you have multiple locations, I would either choose the office location the provider is typically at, or the main office location if there is one. That specific question was not posed and I have not seen official guidance regarding multiple locations, but I can't imagine it matters much unless your locations are in different Medicare jurisdictions.
 
Since Debra is probably tired of saying the same thing in multiple postings, I'll answer and summarize. Everything below is only for providers that may bill E/M services (physicians, nurse practitioners, physician assistants, etc.)
1) Telehealth (which is interactive audio and video, not just telephone) is billed with E/M codes. POS 02. Commercial insurance modifier 95. Medicare no modifier UNLESS you are in a geographic area that was always allowed to bill telehealth, then GT as you would have prior.
Telehealth is typically only for established patients, but CMS has stated they will not look into whether or not you actually saw the patient prior - kind of an don't ask, don't tell policy.
It may be a scheduled visit.
2) Documentation of history, exam & MDM should be done as usual, realizing that exam cannot really be performed. You MIGHT be able to get constitutional (general appearance/vitals) and/or psychiatric (mood, judgment, etc). IF > 50% of visit is counseling, then you may bill based on time, just like for an in person office visit. Again, if billing based on time, that must be documented as well.

A TELEPHONE call is NOT TELEHEALTH. Telephone call must be patient initiated (you may inform pt of the service, but you can't start cold calling your patients and then bill your discussion). Must be established patient. Not originating from a visit in previous 7 days, or resulting in an upcoming appointment at soonest available. Not a scheduled visit. POS 11. Medicare use G2012. Commercial use 99441-99443.

There are also codes 99421-99423 for encounters taking place via your EMR's patient portal. We will not be using those, so I haven't really researched those.

For both telehealth and telephone encounters, you should inform the patient that the discussion is a billable encounter & document their verbal consent in the note. For telehealth you should document the location of the patient, and the location of the provider and of course something noting that the visit took place via interactive audio and video. For telephone, I do not recall seeing any requirement to document patient or provider location, but it certainly can't hurt in case I missed it.

While CMS has specifically stated they will cover these expanded services during the emergency, there is no such guarantee from commercial carriers. Many major carriers have come out with a policy that telehealth and telephone encounters will be covered, but this is not universal.


What happens for appointments (usually routine followups, med checks etc) that are scheduled and the patient does not have video capabilities, so provider completes the visit over the phone only? What codes are used for those situations? They are happening. Do we just use the regular E/M code and modify?
 
Given that Medicare is now covering (as of 3/30/20) Telephone Visits 99421-23. Seeing guidance to use POS 11 if initiated from clinic. If using POS 11, would you append the modifier 95 to the 99421-23?
 
Did anyone every answer this. I am looking for the same information. We were going to go with the regular code and add the 02 POS. We still are not positive
Does anyone know if INITIAL nursing home visits can be billed using telemedicine? I am not really finding anything on it. The list that CMS has as approved codes do not have them listed but that was updated in November and they are not on the list. CPT codes 99304-99306.


Attached is the updated list of approved Medicare Telehealth services from the CMS wesite as of 4/1/2020
 

Attachments

  • List of Medicare Telehealth Svc.pdf
    35 KB · Views: 25
In regards to POS 02 or 11 for other than phone encounters:

Final ruling (as of 4/1/2020) per the Federal Register from the Department of Health and Human Services: Section II

A. Payment for Medicare Telehealth Services Under Section 1834(m) of the Act


To implement this change on an interim basis, we are instructing physicians and
practitioners who bill for Medicare telehealth services to report the POS code that would have
been reported had the service been furnished in person. This will allow our systems to make
appropriate payment for services furnished via Medicare telehealth which, if not for the PHE for
the COVID-19 pandemic, would have been furnished in person, at the same rate they would have
been paid if the services were furnished in person. Given the potential importance of using
telehealth services as means of minimizing exposure risks for patients, practitioners, and the
community at large, we believe this interim change will maintain overall relativity under the PFS
for similar services and eliminate potential financial deterrents to the clinically appropriate use of
telehealth. Because we currently use the POS code on the claim to identify Medicare telehealth
services, we are finalizing on an interim basis the use of the CPT telehealth modifier, modifier
95, which should be applied to claim lines that describe services furnished via telehealth. We
note that we are maintaining the facility payment rate for services billed using the general
telehealth POS code 02, should practitioners choose, for whatever reason, to maintain their
current billing practices for Medicare telehealth during the PHE for the COVID-19 pandemic.
 

Attachments

  • CMS-1744-IFC WEB POSTING MASTER (03-30-20) FINAL 508c.pdf
    860.2 KB · Views: 20
Given that Medicare is now covering (as of 3/30/20) Telephone Visits 99421-23. Seeing guidance to use POS 11 if initiated from clinic. If using POS 11, would you append the modifier 95 to the 99421-23?
Telephone visit codes are 99441-99443
E-visits are 99421-99423
From all the articles I have reviewed thus far (and there are many) no modifiers are required for either of these methods as they are 'non face to face' encounters (with that being said, you may want to check with your local carriers as rules are changing every day)
 
I saw a video from the American Academy of Pediatrics and they are stating that if a telemedicine video/audio visit turns into a curbside for a "swab" then we can code both services on the same claim but use two different place of service codes: example: 99213, 25,95 with pos 2 and 87804 pos 11....has anyone ever done this? I can't find anything with this type of scenario...
Coding During the COVID-19 Pandemic
http://send.mm.aap.org/link.cfm?r=i...Sri0Ld8waYq5WSLw~~&t=AsFn6srIn8MQx7bt8GGzDg~~
 
does anyone have suggestion for a physician that does not have an "office" location where patients are usually seen, now has an RN going to patient home to take COVID-19 swab and set-up the telehealth visit with provider. Since CMS says to bill POS and codes as you normally would, just add modifier 95, i recommended that Home Visit CPT codes 99341-99350 should be billed since under normal circumstances that is what the provider would have billed.

and if this is correct, does anyone have clarification from CMS you can find that allows the home visit to also be coded based on time? all of the CMS releases regarding coding E/M based on time only refer to office visits cpt codes 99205-99215
 
UHC does not want any modifier and neither does medicare. Regular e/m codes with 02 place of service. Horizon, Aetna, AmeriHealth all want GT or 95 modifiers along with place of service 02.
Billing for Professional Telehealth Services During the Public Health Emergency
Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries, CMS will now allow for more than 80 additional services to be furnished via telehealth. When billing professional claims for non-traditional telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE), bill with the Place of Service (POS) equal to what it would have been in the absence of a PHE, along with a modifier 95, indicating that the service rendered was actually performed via telehealth. As a reminder, CMS is not requiring the “CR” modifier on telehealth services. However, consistent with current rules for traditional 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
Traditional Medicare telehealth services professional claims should reflect the designated POS code 02-Telehealth, to indicate the billed service was furnished as a professional telehealth service from a distant site. There is no change to the facility/non-facility payment differential applied based on POS. Claims submitted with POS code 02 will continue to pay at the facility rate
 
https://www.cms.gov/about-cms/emergency-preparedness-response-operations/current-emergencies/coronavirus-waivers

Billing for Professional Telehealth Services During the Public Health Emergency
Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries, CMS will now allow for more than 80 additional services to be furnished via telehealth. When billing professional claims for non-traditional telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE), bill with the Place of Service (POS) equal to what it would have been in the absence of a PHE, along with a modifier 95, indicating that the service rendered was actually performed via telehealth. As a reminder, CMS is not requiring the “CR” modifier on telehealth services. However, consistent with current rules for traditional 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
Traditional Medicare telehealth services professional claims should reflect the designated POS code 02-Telehealth, to indicate the billed service was furnished as a professional telehealth service from a distant site. There is no change to the facility/non-facility payment differential applied based on POS. Claims submitted with POS code 02 will continue to pay at the facility rate
 
https://www.cms.gov/about-cms/emergency-preparedness-response-operations/current-emergencies/coronavirus-waivers

Billing for Professional Telehealth Services During the Public Health Emergency
Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries, CMS will now allow for more than 80 additional services to be furnished via telehealth. When billing professional claims for non-traditional telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE), bill with the Place of Service (POS) equal to what it would have been in the absence of a PHE, along with a modifier 95, indicating that the service rendered was actually performed via telehealth. As a reminder, CMS is not requiring the “CR” modifier on telehealth services. However, consistent with current rules for traditional 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
Traditional Medicare telehealth services professional claims should reflect the designated POS code 02-Telehealth, to indicate the billed service was furnished as a professional telehealth service from a distant site. There is no change to the facility/non-facility payment differential applied based on POS. Claims submitted with POS code 02 will continue to pay at the facility rate

Further Promote Telehealth in Medicare

Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries, CMS will now allow for more than 80 additional services to be furnished via telehealth. During the public health emergencies, individuals can use interactive apps with audio and video capabilities to visit with their clinician for an even broader range of services. Providers also can evaluate beneficiaries who have audio phones only.
In addition, CMS is allowing physicians to supervise their clinical staff using virtual technologies when appropriate, instead of requiring in-person presence
 
Thank you.. have you read the just released MLN matter update regarding modifier CS? Are you interpreting that any visits related to the testing of COVID-19 do not get the modifier?

Families First Coronavirus Response Act Waives Coinsurance and Deductibles for Additional COVID-19 Related Services
The Families First Coronavirus Response Act waives cost-sharing under Medicare Part B (coinsurance and deductible amounts) for Medicare patients for COVID-19 testing-related services. These services are medical visits for the HCPCS evaluation and management categories described below when an outpatient provider, physician, or other providers and suppliers that bill Medicare for Part B services orders or administers COVID-19 lab test U0001, U0002, or 87635.
Cost-sharing does not apply for COVID-19 testing-related services, which are medical visits that: are furnished between March 18, 2020 and the end of the Public Health Emergency (PHE); that result in an order for or administration of a COVID-19 test; are related to furnishing or administering such a test or to the evaluation of an individual for purposes of determining the need for such a test; and are in any of the following categories of HCPCS evaluation and management codes:
  • Office and other outpatient services
  • Hospital observation services
  • Emergency department services
  • Nursing facility services
  • Domiciliary, rest home, or custodial care services
  • Home services
  • Online digital evaluation and management services
Cost-sharing does not apply to the above medical visit services for which payment is made to:
  • Hospital Outpatient Departments paid under the Outpatient Prospective Payment System
  • Physicians and other professionals under the Physician Fee Schedule
  • Critical Access Hospitals (CAHs)
  • Rural Health Clinics (RHCs)
  • Federally Qualified Health Centers (FQHCs)
For services furnished on March 18, 2020, and through the end of the PHE, outpatient providers, physicians, and other providers and suppliers that bill Medicare for Part B services under these payment systems should use the CS modifier on applicable claim lines to identify the service as subject to the cost-sharing wavier for COVID-19 testing-related services and should NOT charge Medicare patients any co-insurance and/or deductible amounts for those services. ????
For professional claims, physicians and practitioners who did not initially submit claims with the CS modifier must notify their Medicare Administrative Contractor (MAC) and request to resubmit applicable claims with dates of service on or after 3/18/2020 with the CS modifier to get 100% payment.
 
I work in a primary care physician office looking to limit patient interaction and primarily use phone or video capabilities. These services are entirely new and never billed prior to the national emergency. I have begun billing 99441-99443, 98966-98962 and G2012. I am trying to gain clarity on Medicare emergency rules giving patients access to telehealth. I am reading it as thought the physician can bill for telehealth if they use Facetime and has been treating patient for 3 years same condition? Any additional information or clarification on this topic would be greatly appreciated.

here are a few sources
see federalregister.gov/d/2020-06990
telephone is under section S

this one defines telephone separately from telehealth

also see donself website he has a free webinar and pdf.
 
Our providers/doctors are now providing after hours telephone services. Is there a code that can be used along with 99441-99443 to denote after hours?
 
What about a telehealth visit performed but the peds provider wants the patient to come to the office for a throat swab or u/a? If billing a telehealth visit can you add the strep test or u/a to billing when billing POS 02?
 
Our providers/doctors are now providing after hours telephone services. Is there a code that can be used along with 99441-99443 to denote after hours?
99050 = Services provided in the office at times other than regularly scheduled office hours, or days when the office is normally closed (eg, holidays, Saturday or Sunday), in addition to basic service
99051 = Service(s) provided in the office during regularly scheduled evening, weekend, or holiday office hours, in addition to basic service

Our main payer is BCBS NC and they informed me we can still bill these codes with telehealth, BUT, I have not gotten any of the claims back yet to see if they are actually paying.
 
Has anyone run into a patient being involved in a car accident and then seeing the provider via telehealth? I am a coder for primary care centers and this happened this morning. I cannot find anything on it.
 
I have a question about the CR modifier. I work in a peds clinic in Oregon and we just started doing telehealth visits. We were just told we need to be appending that mod to our telehealth visits. I think this is HCPCS mod for Medicare only. We do not have any Medicare pt's just commercial and medicaid. Thoughts?
 
We have a situation we aren't really clear on how to code, for a dermatology practice, the provider has asked:

Any idea of how I should bill the following?
I do an evaluation over the phone, then have the patient e-mail me photos that I review and develop an assessment, and then call back and discuss a plan (and call in prescription(s) if needed.

Obviously it depends quite a bit on the payer, but we are generally thinking E/M codes would be the best fit for these, and going by time spent.
 
Was any of the "phone" actually done with video? If so, then E/M are definitely appropriate. If it was telephone only, it seems E/M is not appropriate, unless the specific carrier has instructed audio only is billed with E/M.
If audio only with CMS guidelines, it seems it would be 99441-99443 for telephone, and perhaps G2010 for the "store and forward" reviewing of photos? I do not know the current rules and guidance on billing those together as we never have used G2010 and are not considering it.
Anyone else should feel free to jump in & correct me on this one. :unsure:
 
Was any of the "phone" actually done with video? If so, then E/M are definitely appropriate. If it was telephone only, it seems E/M is not appropriate, unless the specific carrier has instructed audio only is billed with E/M.
If audio only with CMS guidelines, it seems it would be 99441-99443 for telephone, and perhaps G2010 for the "store and forward" reviewing of photos? I do not know the current rules and guidance on billing those together as we never have used G2010 and are not considering it.
Anyone else should feel free to jump in & correct me on this one. :unsure:

There was no video involved for these encounters, but wouldn't G2010 be bundled with the 9944X codes?

99441: Telephone E/M service provided by a physician 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 hrs or soonest available appointment

We are thinking this most accurately describes what we are doing.
 
Right, audio only is 99441-99443; audio with video is E/M. The E/M codes are valued more than the audio only 99441-99443, but if you didn't have video, you can't bill 99441-99443 UNLESS the private carrier (not CMS) advised you may use E/M for audio only. I think United HC is the only one I have heard allowing this.
 
Is there a limit to the number of telephone encounters or telehealth visits during a time frame, as long as they are not related to a previous visit within the last 7 days or end in a decision for a face-to-face visit in the next 7 days?
 
On the idea of a related service, what about patients who have ongoing problems, such as arthritis, and these are previous scheduled follow up visits now being performed by phone? It seems like anything other than emergent circumstances aren't even being considered in all the carriers instructions
 
The AMA coding advice seems to state audio/video or audio only. I will note that it is a little confusing as 99441-99443 are also listed in another column. And there's a statement of "(Flexibility: Permit audio only for E/M telehealth)." Flexibility by who??
The CMS advice clearly states otherwise. I have not seen any commercial insurance guidance that permits E/M when telephone only (I have seen policies stating telephone to be billed with G2012 or 99441-99443, depending on carrier). In our practice, we will only be billing telehealth for audio and video unless CMS provides other guidance.
https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf See Question 8. Specifies AUDIO/VIDEO.
I have found some guidance from private payers, but I had to do alot of digging to find the information at first. Once I found the links though it was easy to go back and reference for updates that seem to happen alot for some of the payers.

This is all as clear as mud at midnight!
 
What are the guidelines for documentations on a telephone visit? I've been sifting through a lot of the data.
Thanks for the help, Jennifer
 
What if provider completes a telehealth visit and decides a true face-to-face exam is necessary? Can you bill the telehealth and regular office visit both on same date of service, by the same provider?
 
What if provider completes a telehealth visit and decides a true face-to-face exam is necessary? Can you bill the telehealth and regular office visit both on same date of service, by the same provider?
The telehealth services should bundle into the face-to-face E/M. You can combine the documentation and bill a higher level if appropriate.
 
The telehealth services should bundle into the face-to-face E/M. You can combine the documentation and bill a higher level if appropriate.
Thank you, Christine! I haven't seen any guidelines for the telehealth visits (99202-99215) like there are for the telephone enounters (99441-99443) bundling the telephone encounter if seen 7 days prior, 24 hours after or at next urgent appointment. Have I just missed those?
 
I'm not considering any new rules. I'm just considering the pre-Covid guidelines for billing 2 visits in the same day. Medicare generally does not permit 2 E/M same day. There are exceptions for unrelated problems which could not have been addressed at the same time.
Medicare claims processing manual section 30.6.7.B
B. Office/Outpatient E/M Visits Provided on Same Day for Unrelated Problems
As for all other E/M services except where specifically noted, the Medicare Administrative Contractors (MACs) may not pay two E/M office visits billed by a physician (or physician of the same specialty from the same group practice) for the same beneficiary on the same day unless the physician documents that the visits were for unrelated problems in the office, off campus-outpatient hospital, or on campus-outpatient hospital setting which could not be provided during the same encounter (e.g., office visit for blood pressure medication evaluation, followed five hours later by a visit for evaluation of leg pain following an accident).
 
New question on telephone only codes. Here's the scenario, patient comes in for in office visit, Dr. orders CT scan, within 7 days of office visit, patient has telephone only visit with Dr. to go over CT scan results. Normally would bill 99441-3 but because within 7 days of original in office visit can't use these codes. How do I code the telephone only visit?
 
You can’t bill for this. It’s considered to be included in the original E/M. There’s no other way to code it.
New question on telephone only codes. Here's the scenario, patient comes in for in office visit, Dr. orders CT scan, within 7 days of office visit, patient has telephone only visit with Dr. to go over CT scan results. Normally would bill 99441-3 but because within 7 days of original in office visit can't use these codes. How do I code the telephone only visit?
 
You can’t bill for this. It’s considered to be included in the original E/M. There’s no other way to code it. IF you can justify another E/M visit with documentation from the call, (if normally the patient would have come in to discuss results and you would have billed it that way) THEN you can bill another separate E/M with POS 02 and whatever modifier the patient’s plan wants for telephone.
 
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