Coronavirus Medicare Telehealth Waiver FAQ

Coronavirus Medicare Telehealth Waiver FAQ

Your frequently asked questions, answered.

In a previous post in the AAPC Knowledge Center, we noted that, on March 17, 2020, Medicare relaxed its telehealth regulations to facilitate healthcare for the elderly and others affected by the COVID-19 pandemic for the duration of the national public health emergency.
Specifically, 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 risk of exposure and spread of this virus,” according to Centers for Medicare & Medicaid Services Administrator Seema Verma.
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.
UPDATE:
Don’t miss AAPC’s webinar: Telehealth and other Remote Services from a Physician’s Office, March 31, presented by Jill M. Young, CPC, CEDC, CIMC. She will discuss the diagnosis and testing codes for COVID-19, explain the guidelines for remote patient care while the telehealth waiver is in force for Medicare patients, and much more!

Virtual Check-In

What is the service? 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.
Who can receive the service? Only established patients may receive these services.
Who can provide the service? Only providers who can perform and bill E/M services may bill for virtual check-ins.
How do I code the service? 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.
What else should I know about this service? Make sure your documentation includes medical necessity and verbal patient consent.
Which telemedicine codes are NOT part of the Medicare 1135 waiver? The CPT® equivalent codes — 99441 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, 9944211-20 minutes of medical discussion, and 9944321-30 minutes of medical discussion are currently not listed among the telehealth codes listed in the Medicare 1135 waiver.
Additionally, 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 nonphysician 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 9896821-30 minutes of medical discussion.

E-Visit

What is the service? The service describes patient-initiated communications through electronic health record (EHR) portals, secure email, or other digital applications.
Who can receive the service? Only established patients may receive these services.
Who can provide the service? See the coding information below.
How do I code the service? Use 99421 Online digital evaluation and management service, for an established patient, for up to 7 days, 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, 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.
No modifiers are needed with these codes.
What else should I know about this service? Make sure physician documentation includes patient consent.

Medicare Telehealth Visits

What are these services? These are services that would generally be conducted face-to-face but that can also be furnished via “an interactive audio and video telecommunications system that permits real-time communication between the distant site and the patient,” according to the Medicare Telemedicine Health Care Provider Fact Sheet.
Who can receive the services? Usually, 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,” according to the Medicare Telemedicine Health Care Provider Fact Sheet.
Who can provide the services? “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.
How do I code these services? The service must be listed in CMS’s list of telehealth services. Examples of common services that can be furnished via telehealth include 99201-99215 Office or other 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.
Do I need a modifier for these services? 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 GT modifier.

Bruce Pegg

71 Responses to “Coronavirus Medicare Telehealth Waiver FAQ”

  1. Debaleena Halder says:

    Hi,
    Thank you for putting this up for us. While evaluating via telehealth visit, how can one give the levels of 99201 to 99215 without checking the vitals and PE? Is there any rules announced for that? Or should one switch to the telemedicine codes 99441.. series given there is some flexibility now?

  2. Renee Dustman says:

    Response from the author:
    It is possible to record 99201-99215 without an exam. If you are working with an established patient, an exam (including vitals) is not necessary if the other two elements (history and medical decision making, or MDM) are met. You also have the option of determining the level of E/M based on time if counseling takes up more than 50 percent of the encounter.
    However, as Medicare has just allowed 99201-99215 for new patients under the 1135 Waiver, if you do not determine the E/M level based on time and have to record an exam, you should note that Medicare recognizes seven vital signs (sitting or standing blood pressure, supine blood pressure, pulse rate and regularity, respiration, temperature, height, and weight) along with general appearance as a part of the constitutional system exam. Under 1995 guidelines, only one vital sign is needed; under 1997, you need three.
    So, if your provider documents the patient’s general appearance and records one vital sign, you would have enough to document that an exam had been performed under 1995 guidelines.

  3. Jeff MD says:

    Am I correct in understanding that codes such as 99213, 99214 and 90836 will be paid by medicare at a lower-than-usual office rate, since they have to be billed as institutional? (As far as I can tell, the office rate is higher than the institutional rate) So essentially, reimbursement will go down? It appears that for 99213/4 and 90836 the payments are like 30% lower. Thanks!

  4. Jeff MD says:

    Wanted to confirm this was understood correctly: so, for example for telepsychiatry, codes 99213, 99214 and 90836 can be billed, but compared to the office rate, because for telehealth it is required to bill as POS 02, the reimbursement will be signfiicantly (around 30%) lower? Is that correct? 🙁

  5. Faith Del Percio says:

    Does this apply to chiropractors, who can bill E/M exams? Will medicare pay for these services, performed by a chiropractor?
    Thank you

  6. Susan Nodine CPC CPMA ROCC says:

    Are nutritionists codes 97802 and 97803 included under the waiver? Our nutritionist needs to move some of our diabetic patients with other comorbidities to a telemedicine visit.

  7. Anthony Bovier says:

    Great article. I have a question regarding incident-to billing for codes 99212-99215 while patient is home but NPP is in the office providing telehealth services under the direct supervision of a physician. I am not able to find any guidance on this and if Incident-to can apply when billing under POS 02.

  8. Joanna says:

    Where is it in writing from Medicare that states you can see a new patient? The 1135 waiver only states that HHS will not audit to ensure that such a prior relationship existed for claims submitted during this public health emergency

  9. Nicole S says:

    What place of service do commercial payers require. Does BCBS also require the POS to be 2 like Medicare?

  10. Jenny D says:

    Is there any documentation that says what information clinical staff should document to support the coding of the telehealth visit/e-visit/ or virtual check in?

  11. Renee Dustman says:

    Hi Folks,
    Please be patient as we work to answer your questions!

  12. Tammy Etzel says:

    Can you tell us how we would bill NON Medicare patients such as Medicaid or Commercial patients calling in from home and having a telehealth visit with the physician? I work in an FQHC so we bill Encounters. Please advise, we are going to start very soon and I do not know how to bill it. Thank you!

  13. Renee Dustman says:

    From the author:
    If you have previously successfully billed Medicare for chiropractic office E/Ms, it would make sense that Medicare would also pay for telehealth E/Ms now. But this question is probably best answered by your MAC, as Medicare chiropractic rules are stricter than most specialties.

  14. Stacy Chaplain says:

    From the author:
    These services are on the list of Medicare telehealth services mentioned above and so should be eligible for payment.

  15. Stacy Chaplain says:

    From the author:
    You are correct. The actual wording of the fact sheet reads: “To the extent the 1135 waiver requires an established relationship, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency.” So, Medicare is not saying you can see new patients via telehealth, but that it is going to turn a blind eye if you do during the emergency.

  16. Stacy Chaplain says:

    From the author:
    BCBS may have different guidelines regarding telehealth coding. You would have to check with your BCBS representative on this to see if they follow Medicare’s requirements regarding the use of the 02 POS modifier.

  17. Stacy Chaplain says:

    From the author:
    Telehealth services should be documented in exactly the same way you would document face-to-face services. You should also add a statement to the effect that the service was provided using telemedicine, and document the patient’s location, the provider’s location, and the names and roles of anyone participating in the encounter.

  18. Kristina says:

    Can you please address the telephone encounter codes and the pos for them as well?

  19. Sommer Cunningham says:

    Please update this article!!!! This is very misleading. Medicare DID NOT say that you are allowed to bill a new patient for telemedicine via video and audio per their Medicare Telemedicine Health Care Provider Fact Sheet. They only said that they will not be performing audits in the future for new patients being billed for telehealth medicine during this time of emergency. That doesn’t mean that private payers won’t do an audit in the future. ***Not doing an audit in the future does not equate to something being “allowed”. (Please also understand I am only talking about video and audio telemedicine).

  20. Deb Boyd says:

    we are not set-up to bill “telehealth” nor are we in a rural area….. however based on the 1135 waiver IF we “call patients via telephone only” do we bill e/m codes(99213, etc) – with POS 2 ??? and the Provider can call from home or office setting….and the patient will be in their home??….my interpretation

  21. Angel Morency says:

    Are you suppose to bill for both CPT codes on one claim form or is it one or the other? example
    line one- CPT code 99213 with modifier 95 then line 2 CPT code 99442
    or is it one
    if you bill for CPT code 99442 then do no try to bill for 99213 w/mod 95

  22. Debaleena Halder says:

    “From the author:
    You are correct. The actual wording of the fact sheet reads: “To the extent the 1135 waiver requires an established relationship, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency.” So, Medicare is not saying you can see new patients via telehealth, but that it is going to turn a blind eye if you do during the emergency.”
    Does the above statement means the provider should bill an established CPT even if its a new patient?

  23. Renee Dustman says:

    no

  24. Renee Dustman says:

    You are correct Sommer. This does not give everyone carte blanche to commit Medicare fraud.

  25. Renee Dustman says:

    Please refer to the following CMS toolkit for telehealth questions:
    https://www.cms.gov/files/document/general-telemedicine-toolkit.pdf

  26. Kelly Corbett says:

    Can the providers bill for new patient initial telephone visits, not online video, if it does not lead to a face to face visit within 7 days during this health crisis? I do see the relaxed waiver comments for established patients for telehealth, but I’m specifically looking for initial telephone calls or consults. I apologize if this has been asked and answered.

  27. tj says:

    Great article. I have a question regarding incident-to billing for codes 99212-99215 while patient is home but NPP is in the office providing telehealth services under the direct supervision of a physician. I am not able to find any guidance on this and if Incident-to can apply when billing under POS 02

  28. Sheri Myers says:

    “I have a question regarding incident-to billing for codes 99212-99215 while patient is home but NPP is in the office providing telehealth services under the direct supervision of a physician. I am not able to find any guidance on this and if Incident-to can apply when billing under POS 02.” Anthony, I have the same question!

  29. Susan Taylor says:

    Can you enlighten us about 1 hr psychotherapy session both individual and family within the new Covid waiver parameters. We are interested in the rules for all practioners, cliniclal nurse specialist, nurse practioners, social workers and physicians. Are they coded as before and billed at the same rate? If so then we document where and with whom the session occurred? Is there anything else about coding a billing we need to know?

  30. Renee Dustman says:

    Please refer to the following resources and/or contact the payer for specific coding guidance.
    https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf
    https://www.cms.gov/files/document/general-telemedicine-toolkit.pdf
    You can also use AAPC’s Ask an Expert service for specific guidance.

  31. Erin King says:

    We are a specialist group wanting to bill telehealth but do NOT have an online portal how would we go about billing since they will not be conducting a normal E & M?

  32. Laura says:

    So my provider did a phone call visit and what I am understanding is that I can bill 99441 with POS 02? IS that the right form to bill in this situation?

  33. Alanna Palmer says:

    Can you explain the modifier CR a bit more? Does it need to be used in these circumstances on every telehealth visit and check in visits also?

  34. sheila says:

    can you use codes 99421- 99243 for telephone calls or does this have to require on line portal??? In our community they are saying that medicare is allowing this because of crisis. I cant find where it says you can use a telephone anywhere with these codes. thanks

  35. Renee Dustman says:

    Alanna,
    CMS just issued SE20011, to add the following paragraph:
    … telehealth claims don’t require the “DR” condition code or “CR” modifier. CMS is not
    requiring additional or different modifiers associated with telehealth services furnished
    under these waivers. However, consistent with current rules, there are three scenarios
    where modifiers are required on Medicare telehealth claims. In cases when a telehealth
    service is furnished via asynchronous (store and forward) technology as part of a federal
    telemedicine demonstration project in Alaska and Hawaii, the GQ modifier is required.
    When a telehealth service is billed under CAH Method II, the GT modifier is required.
    Finally, when telehealth service is furnished for purposes of diagnosis and treatment of
    an acute stroke, the G0 modifier is required.

  36. Keshia Jackson says:

    What happens if a fellow or resident performs this services? Can the attending attest?

  37. Charles DiGiacomo says:

    For the covered Medicare telehealth visits that are being billed as a 99201-99205 or 99211-99215, it states that the telecommunication systems is audio and video. I just want to clarify that if our providers only speak with the patient on the telephone with no video link set up, does that mean we can only bill for the virtual check-ins and not an OV code. The providers usually spend about 20 minutes on the phone during these visits and complete an entire SOAP note besides the vitals section. Basically I am trying to clarify if in order to bill for a telecommunication visits for Medicare as a normal E/M OV code, does the service have to be audio AND video?

  38. Christine says:

    There have been questions as to whether an AWV (Medicare Wellness Visit) can be done by telehealth. Does anyone know if that is acceptable?

  39. Amber Lomax says:

    How do we bill assisted living visits via telehealth? I tried 99336 mod 95 with POS 02 and got denials saying missing/incomplete/invalid/inappropriate place of service.

  40. Kylena says:

    ““I have a question regarding incident-to billing for codes 99212-99215 while patient is home but NPP is in the office providing telehealth services under the direct supervision of a physician. I am not able to find any guidance on this and if Incident-to can apply when billing under POS 02.” Anthony, I have the same question!” I also have the same question about this as well. I have been researching and cannot find anything in regards as to whether or not this is allowed. Does anyone know if we can bill incident-to for TeleHealth? The doctor I work for is really wanting a distinct answer.

  41. Renee Dustman says:

    I have not come across incident-to guidelines during the waiver but MLN Matters SE20011 says:
    “A range of providers, such as doctors, nurse practitioners, clinical psychologists, and licensed
    clinical social workers, will be able to offer telehealth to their patients.”

  42. Renee Dustman says:

    Medicare will pay telehealth at office visit rates.

  43. cathy tucker says:

    I am trying to see if FQHC’s can bill as a distant site according to this waiver. I know that some states have gotten a 1135 waiver to allow this; however I need to know about Alabama.

  44. Robin Miller says:

    Can you code and bill Telehealth visits if the provider is at their home and has remote access to the patients chart?

  45. Adrienne says:

    I’m looking for documentation requirements for our providers. We bill codes 99307-99310 which is different then most topics of conversation. CMS shows currently that those codes are only payable once every 30 days but I’m not seeing where this is waived as well.

  46. nicole karisny says:

    commical ins 99212-99214 modifier? and any special codes other that the ov?
    called fed bcbs they wont tell me a damn thing

  47. Linda Arpino says:

    I’m a registered dietitian in private practice and use only codes 97802. & 97803. I am doing real time video teleconsults and was billing Using pos 11 with modifier 95, will that suffice or are others recommended. I get referrals from a wide variety of MDs but work independently.

  48. Renee Dustman says:

    Bill as usual. The coding hasn’t changed. The waiver simply allows qualified professionals to provide telehealth to patients in their home.

  49. Renee Dustman says:

    POS 02 for Medicare; POS 02 or Modifier 95 for commercial, depending on payer.

  50. Renee Dustman says:

    The waiver only expands the distant site of service to homes. There is no mention of any other flexibility.

  51. Renee Dustman says:

    yes, as long as the provider is a qualified healthcare professional permitted to perform telehealth services

  52. Susanne Leader says:

    Can I bill 99421- 99243 for telephone calls or does this have to require on line portal. Is the POS 02?

  53. Renee Dustman says:

    Susanne: CPT 99421-99243 describe established patient online visits in a patient portal. What you can bill depends on who’s providing the service and what service is provided. POS 02 is for traditional telehealth codes. For nontraditional telehealth services, CMS says, “… 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 is to ensure proper payment. CMS goes on to say “… 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.”

  54. Angela Christie says:

    For telephone code 98966-98968, can 40 minutes be coded with 98966 and 98968 to add up to the 40 minutes OR can we only code 98968 as the top time allowed? CCI allows the codes to be billed together but I’m unable to find anything to state this is acceptable or no this is not how the codes were meant to be used. Thanks for your time.

  55. Josie Gunn says:

    On, Friday, April 3, 2020, Medicare did extend the services it will cover under the waver to include 99441-99443 and 98966-98968 (for NPP) but it does not state what place of service should be used. This information was obtained from the White Pages provided by Morgan Lewis group out of Washington, D.C. My question is, can these range of codes apply to hospital visits?

  56. Renee Dustman says:

    Angela, I don’t think you can bill the codes together for the same date of service. You may be able to use a prolonged services code, if applicable.

  57. Hima says:

    How about Medicaid? I am in Illinois. Does Medicaid require modifier 95 with teleheath E/M visit codes or GT and POS 02? They do require GT and POS 02 for other telecommunication codes?

  58. Teresa says:

    I have a question regarding incident-to billing for codes 99212-99215 while patient is home but NPP is in the office providing telehealth services under the direct supervision of a physician. I am not able to find any guidance on this and if Incident-to can apply. I also received info that we should not bill 02 that we should bill 11(office) and 95 modifier because it says bill as you normally would. what do you think?

  59. Jayita says:

    Any documentation guidelines for codes G0508 and G0509.?How they differ from 99291 and 99292 , now that both can be billed under telehealth.

  60. Alejandro Cardona says:

    We just spent sometime with a UHC representative and they would not guide us into what code we could use for a Telephone Conversation with a patient. The CPT code we billed was 99442 (telephone evaluation and management service by a physician …11-20 min) and they rejected the claims as NOT REIMBURSABLE for a patient that was over 65 years old. We were pointed to their latest bulletin.
    Does anybody out here know what they would want? TX for your input.
    https://www.uhcprovider.com/content/dam/provider/docs/public/policies/medicaid-comm-plan-reimbursement/UHCCP-Telehealth-and-Telemedicine-Policy-(R0046).pdf
    Telephone Services:
    UnitedHealthcare Community Plan follows CMS guidelines which do not allow reimbursement for telephone services which are non-face-to-face evaluation and management services by a Physician or Other Qualified Health Care Professional reported with CPT codes 98966-98968 or 99441-99443. They are non-reimbursable codes according to the CMS Physician Fee Schedule (PFS) and are considered an integral part of other services provided.

  61. Gulnar says:

    When does the crisis period end for televisit

  62. Renee Dustman says:

    Nobody knows.

  63. Renee Dustman says:

    Angela: According to CMS, “… there are no CPT codes available to describe medical discussions lasting longer than 30 minutes.” https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf

  64. Renee Dustman says:

    Hima, We do not report on Medicaid. You will need to contact your state Medicaid dept.

  65. Renee Dustman says:

    Teresa, For the most up to date info, check out this CMS FAQ https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf

  66. Renee Dustman says:

    Per this FAQ https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf “We expect the same level of documentation that would ordinarily be provided if the services furnished via telehealth were conducted in person.”

  67. Renee Dustman says:

    Please post questions that extend beyond the scope of this article in the AAPC coding forum.

  68. pat ramapuram says:

    Any advice? i have a provider interchangeably using 99422 and 99442

  69. Renee Dustman says:

    Pat,
    The code descriptors are very different so it’s unlikely your provider should use either code for the same type of service. Although Medicare is waiving the “established patient” part during the COVID-19 public health emergency, the rest of the requirements are not.

    99422 Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 11-20 minutes
    99442 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; 11-20 minutes of medical discussion

    The provider should document which mode of communication is being used so you are able to select the appropriate code.

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