Telehealth FAQ: You Asked, We Answered

Telehealth FAQ: You Asked, We Answered

Certain telemedicine services are already covered under the Physician Fee Schedule (PFS) when provided to Medicare patients in accordance with regulations. In response to the public health emergency (PHE) for the COVID-19 pandemic, the Centers for Medicare & Medicaid Services (CMS) has temporarily expanded telehealth coverage.
Effective March 6, CMS expanded the telehealth benefit under the Section 1135 waiver authority and Coronavirus Preparedness and Response Supplemental Appropriations Act. Under the wavier, Medicare can pay for office, hospital, and other visits furnished via telehealth across the country, including in patients’ homes. Since issuing the Section 1135 waiver, CMS has issued additional waivers and relaxed more regulations pertaining to Medicare-covered entities. Policy changes are outlined in an interim final rule with comment period.
Although there are no new codes associated with the telehealth policy changes (aside from the new COVID-19 diagnosis and testing codes), many medical coding questions remain. Here are some frequently asked questions (FAQ), which we have done our best to answer.


Disclaimer: Information related to COVID-19 is changing rapidly. This information was accurate at the time of writing. Please continue to check payer websites, CMS, CDC, and AAPC’s Knowledge Center for the most up-to-date information.


What code can the PCP bill for specimen collection?
Q: Hello, do you know if the PCP office can bill any codes for the collection of the specimen (swab) of COVID-19 testing? I have a scenario where the PCP office is collecting the swab but then sending the specimen to outside lab for processing. What code can the PCP bill?
A: If the swab is collected during an E/M in-person visit, it is included in the E/M code. If the patient encounter is for just the swab performed at the office or group practice’s testing site, bill CPT® 99211 (add modifier 25 if this occurs the same day as the assessment). If the patient is swabbed at an independent testing site, the testing site bills CPT® 99001. The lab that performs the test bills CPT® code 87635 (for dates of service on or after March 13, 2020) or new HCPCS Level II codes U0001-U0002 (for dates of service on or after Feb. 4, 2020). Labs may bill U0002 for tests described by 87635 until it is implemented.
For the PHE for the COVID-19 pandemic only, CMS will allow a specimen collection fee for sputum collection performed by trained laboratory personnel. CMS is establishing two new HCPCS Level II codes: G2023-G2024.
COVID-19 tests that allow patients to collect the specimen themselves are not eligible for the specimen collection fee.
Are telephone calls a telehealth service?
Q: 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?
A: CMS states in the interim final rule, “We expect physicians and other practitioners to use the E/M code that best describes the nature of the care they are providing, regardless of the physical location or status of the patient.” In other words, bill the most appropriate E/M code that describes the service rendered. Append modifier 95 to indicate that the service was conducted using telehealth (which is loosely translated during the PHE for COVID-19).
Who may perform telehealth services?
Q: What happens if a fellow or resident performs this service? Can the attending attest?
A: Distant site practitioners who can furnish and get payment for covered telehealth services (subject to state law) include physicians, nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologists, clinical social workers, registered dietitians, and nutrition professionals. CMS is allowing physicians to supervise their clinical staff using virtual technologies when appropriate, instead of requiring in-person presence. On an interim basis for the duration of the PHE for the COVID-19 pandemic, CMS is revising their regulations to specify that Medicare may make payment under the PFS for teaching physician services when a resident furnishes telehealth services to beneficiaries under direct supervision of the teaching physician by interactive telecommunications technology. Additionally, Medicare may make payment under the PFS for services billed under the primary care exception by the teaching physician when a resident furnishes telehealth services to beneficiaries under the direct supervision of the teaching physician by interactive telecommunications technology. (MLN Connects Special Edition, March 31)
How do I bill telephone calls without video?
Q: Can you use codes 99421-99423 for telephone calls or does this have to require online portal? In our community they are saying that Medicare is allowing this because of crisis. I can’t find where it says you can use a telephone anywhere with these codes.
A: For the duration of the PHE for the COVID-19 pandemic, Medicare will make separate payment for CPT® codes 98966-98968 and 99441-99443, with work RVUs based on calendar year PFS 2008 rulemaking.
Also, for the duration of the PHE, CMS is extending CPT® 99421-99423 and HCPCS Level II codes G2016-G2062 to new patients who pose an exposure risk. That is the only change to these codes.
When do I use modifier CR for telehealth?
Q: Does modifier CR need to be used in these circumstances on every telehealth visit and check-in visits also?
A: 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.
What is the POS for telephone calls?
Q: 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?
A: When a physician or practitioner submits a claim for their services, they include a POS code, which determines whether the service is paid using the facility or non-facility rate. CMS is maintaining the facility payment rate for services billed using POS 02 Telehealth.
Under the waiver, however, CMS is instructing physicians and nonphysician practitioners (NPPs) who bill for Medicare services via telecommunications to report the POS code that would have been reported had the service been furnished in person, with CPT® telehealth modifier 95.
How do we bill telehealth without an E/M visit?
Q: 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?
A: Telemedicine interactions between practitioner and patient via telecommunication can be divided into four forms of virtual services as defined by Medicare Part B:

  • Medicare telehealth visits
  • Virtual Check-ins
  • E-visits
  • Remote monitoring

CMS states in the interim final rule, “We expect physicians and other practitioners to use the E/M code that best describes the nature of the care they are providing, regardless of the physical location or status of the patient.” Although a device capable of audio and video is usually required, during the PHE for the COVID-19 pandemic, CMS is allowing audio-only devices to conduct virtual check-ins (HCPCS Level II code G2012 or CPT® 99421-99423, depending on payer).
Are psychotherapy sessions billed at the same rate?
Q: Can you enlighten us about 1 hour psychotherapy session both individual and family within the new COVID waiver parameters. We are interested in the rules for all practitioners, clinical nurse specialist, nurse practitioners, 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?
A: For the duration of the PHE for COVID-19, Medicare Part B pays for office and other outpatient visits, professional consultation, psychiatric diagnostic interview examination, individual psychotherapy, pharmacologic management, and end stage renal disease-related services included in the monthly capitation payment furnished by an interactive telecommunications system when the usual conditions are met, as outlined in the Medicare Claims Processing Manual. (CMS-1744-IFC § 410.78)
Do we bill telehealth via telephone with E/M codes?
Q: 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?
A: Coding depends on what the encounter is for and who the payer is. If the qualified healthcare practitioner (QHP) is providing an  evaluation and management (E/M) service via telephone, bill the telehealth E/M codes. If the QHP is providing only a virtual check-in, bill CPT® code 99421-99423 or HCPCS Level II code G2012 (for Medicare).
CMS is waiving distant and originating site restrictions during the PHE for COVID-19 and instructs us to report the QHP’s POS with modifier 95. “We expect physicians and other practitioners to use the E/M code that best describes the nature of the care they are providing, regardless of the physical location or status of the patient,” CMS states in the interim final rule with commend period.
Commercial payer policies may vary.
Does incident-to apply when billing 99212-99215 in POS 02?
Q: 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.
A: CMS is allowing physicians to supervise their clinical staff using virtual technologies when appropriate, instead of requiring in-person presence.
How do I bill non-Medicare patients for telehealth?
Q: 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.
A: CMS is approving Medicaid Section 1135 waivers for states in response to COVID-19. Check with your state’s Medicaid office for specific guidance. Commercial payers will also be issuing proprietary guidance so please check their websites.
Do I bill E/M and telehealth services separately?
Q: Are you supposed to bill for both CPT® codes on one claim form or is it one or the other? Example: line one- CPT code 99213-95, line two- CPT code 99442; or CPT code 99442.
A: To bill 99441-99443 and an evaluation and management (E/M) service such as 99213, you must follow CPT® guidelines, which state, “If the telephone service ends with a decision to see the patient within 24 hours or next available urgent visit appointment, the code is not reported; rather the encounter is considered part of the preservice work of the subsequent E/M service, procedure, and visit. Likewise, if the telephone call refers to an E/M service performed and reported by that individual within the previous seven days (either requested or unsolicited patient follow-up) or within the postoperative period of the previously completed procedure, then the service(s) is considered part of that previous E/M service or procedure.”
Provided the documentation shows there is no relationship between the 99213 and 99442, you can then bill for both services using modifiers 25 and 95 on the 99213. However, if the 99442 resulted in the 99213 within 24 hours, or if the 99442 was a follow-up to the 99213 within the previous seven days, you can only bill for the 99213 with modifier 95, or with modifier 02 if that is your payer’s preference.
Do I bill a new patient as an established patient for telehealth?
Q: Should the provider bill an established CPT code even if it’s a new patient?
A: Report the code that best describes the service. CMS states in the interim final rule, “While some of the code descriptors refer to ‘established patient,’ during the PHE, we are exercising enforcement discretion on an interim basis to relax enforcement of this aspect of the code descriptors.”
How do we level E/M services provided via telehealth?
Q: While evaluating via telehealth visit, how can one give the levels of 99201 to 99215 without checking the vitals and PE? Should one switch to the telemedicine codes 99441 series given there is some flexibility now?
A: On an interim basis, CMS is revising their policy to specify that the office/outpatient E/M level selection for these services when furnished via telehealth can be based on medical decision making (MDM) or time, with time defined as all the time associated with the E/M on the day of the encounter; and to remove any requirements regarding documentation of history and or physical exam in the medical record. Good practice for 2021!
What are the rates for telehealth codes?
Q: 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.
A: During the PHE for COVID-19, Medicare will pay the non-facility rate for face-to-face professional services provided via telehealth. Append modifier 95 to the code and report the POS code for the setting in which the service would be provided under normal circumstances.
Can chiropractors bill E/M exams via telehealth?
Q: Does the telehealth waiver apply to chiropractors who can bill E/M exams? Will Medicare pay for these services performed by a chiropractor?
A: 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.
What are the documentation requirements for telehealth services during the waiver?
Q: 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?
A: Telehealth services should be documented the same way you would document face-to-face services. You should also add a statement to the effect that the service was provided non-face-to-face, and document the patient’s location, the provider’s location, and the names and roles of anyone participating in the encounter. Note that, on an interim basis, CMS is removing any requirements regarding documentation of history and/or physical exam for telehealth services (although, these elements should still be provided).
What place of service do I use for commercial payers?
Q: What place of service do commercial payers require. Does BCBS also require POS 2 like Medicare?
A: Most BlueCross BlueShield companies recognize POS code 02 for telehealth. You should check with your specific payer before using it, however, as some may prefer CPT® modifier 95, while others may prefer modifier GT.
Will I be audited for telehealth services?
Q: 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.
A: The actual wording of the CMS 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.”
Can nutritionists bill telehealth services?
Q: 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.
A: These services are already on the Medicare Telehealth Code List, so they should be eligible for payment.
Can an AWV be conducted via telehealth?
Q: Can an annual wellness visit be done via telehealth?
A: Established patient AWV codes G0438 and G0439 are both on the Medicare Telehealth Code List, so, yes, an AWV can be performed via telehealth. Note these codes generally cannot be billed more than once within 12 months. However, CMS is waiving limitations for many E/M codes during the PHE for COVID-19 pandemic.
The initial preventive physical examination (IPPE) or Welcome to Medicare visit (G0402) is not on the Medicare Telehealth Code List, so it cannot be performed via telehealth.
How do we bill assisted living visits performed via telehealth?
Q: How do we bill assisted living visits via telehealth? I tried 99336-95 with POS 02 and got denials saying missing/incomplete/invalid/inappropriate place of service.
A: CPT® 99336 has been temporarily added to Medicare Telehealth Code List. Append modifier 95 and the provider’s billing POS.

Evaluation and Management – CEMC

Bruce Pegg

68 Responses to “Telehealth FAQ: You Asked, We Answered”

  1. Ashley says:

    Hi there, are office has starting using cpt codes 99441-99443 and 98966-98968 during the covid pandemic. How would we bill for a phone call that is 45 or 60 minutes long? Do the same set of rules apply to each code set?

  2. Renee Dustman says:

    Ashley: We don’t have official language to guide you on your specific question. Here’s what CMS says in the interim final rule: “We are finalizing, on an interim bases for the duration of the PHE for the COVID-19 pandemic, separate payment for CPT codes 98966-98968 and CPT codes 99441-99443.” Work RVUS are given, as well (on page 129). The agency goes on to say, “… While some of the code descriptors refer to ‘established patient,’ during the PHE we are exercising enforcement discretion on an interim basis to relax enforcement of this aspect of the code descriptors.” Note that 98966-98968 describe assessment and management services performed by NPPs who cannot separately bill for E/Ms. However, CMS says, “We are noting that these services may be furnished by, among others, LCSWs, clinical psychologists, and physical therapists, occupational therapists, and speech language pathologists when the visit pertains to a service that falls within the benefit category of those practitioners. To facilitate billing of these services by therapists, we are designating CPT codes 98966-98968 as CTBS ‘sometimes therapy’ services” … which will require the corresponding GO, GP, or GN therapy modifier.

  3. Ronald Hirsch says:

    Was the ability to bill 99211 simply to collect a specimen and send it to the lab new for COVID?
    If a doctor is in the hospital hallway or nurse’s station and the patient is in the room and the doctor uses FaceTime to communicate and does not enter the room, is this telehealth -95 or a “regular” visit with no modifier?
    I don’t agree above that “telephone only with no video” can be billed with office visit codes. Telephone only is 99441-3 if it is a “regular visit.”

  4. Sheryn Gorman says:

    I wasn’t sure and was looking at 99441-99443 to use for billing for telephone calls, so if I am reading this correctly…Our office is not set up for virtual visits, we are performing all E/M’s via telephone only. But, with the 1135 waiver, we able to use E/M’s 99201-99205 or 99211-99215, with a 95 modifier or 02 POS if necessary depending on payer?

  5. Eileen Wiedemann says:

    Will Medicare pay for cpt codes 99442-99443 for telephone visits that are more than 10 minutes
    For Medicare:
    Does visits for 5-10 minutes of medical discussion get billed under G2012 for Medicare patients
    and visits from 11-20 minutes get billed with 99442. And visits 21+ minutes get billed under 99443
    Or will they discard G2012 code completely and just use codes 99441-43

  6. Christine says:

    Your answer about telephone audio only service was not correct. CMS clearly commented for using the regular office visit codes for telehealth service, the transmission should be both audio and video. For telephone using audio only service, for Medicare, there is only one code you can use, which is G2012 for short 5-10 min telephone communication. For other insurances like BCBS or Harvard, there are other particular codes for telephone based audio only services such as 99441 to 99443 for physicians. You should check each payer’s particular codes for that. Also for Medicare, both audio and video using telehealth services don’t require any modifier. You only need regular visit codes with the POS of 02.

  7. Angel says:

    In order to bill for a new patient we must have a PE, how are we going to handle this part? Are we assuming that we will not charge for new patients at all?

  8. Bambi Wood says:

    Greetings, thank you very much for your guidance. Regarding the question above related to billing 99211 for the specimen collection, would you clarify if the incident-to guidelines regarding an established problem/plan of care is exempt? The presenting problem is not established (i.e. diagnosis of signs or symptoms that may indicate COVID).

  9. Himani says:

    In regards to last question, for telehealth to patients iin asst living, would coding 99336 with modifier 95 and POS 13 work as with changes under 1135 waiver?

  10. Renee Dustman says:

    yes

  11. Tracy Knipstein says:

    Do the telephone calls that are billable to Medicare require a teaching physician attestation? I know for the video communication physicians can supervise a resident using vitrual technologies versus the in-person presence. I am wondering specifically what supervision would be required for 99441-99443.

  12. Amanda Shepard says:

    You mentioned 99336 is not on the telehealth approved codes for Medicare, however it has been added as an approved code. All home visit codes and ALF visit codes are included.

  13. Susan Frank says:

    Is it possible to bill preventive health codes 99381-99397 via telehealth (to non-Medicare payors)? We have physicians who want to do WellChild Checks via telehealth and we are receiving very mixed messages from our insurance providers.
    Thank you

  14. Jennifer Swartwood says:

    So 99441-99443 codes for telephone only state they must be initiated by the patient, meaning your patient calls in with concerns and then actually speaks to a provider and they turn that call into a visit. What do you bill for the scenario that patient has been booked for an appointment but because of this pandemic that pre-booked appointment tuned into a audio only call because the patient doesn’t have capabilities to use video, call is documented as such, non face to face and do to Medicare’s new guideline for telehealth to bill as you would have if the visit was face to face can we bill using the 99201-99205 or 99212-99215 CPT codes with 95 modifier? I have been reading so much about the 99421 – 99423 (virtual check -in done by an email) & 99441-99443 (Telephon only) codes but those are all initiated by the patient.

  15. Lillian says:

    I agree with Christine, evaluations performed via telephone cannot be billed with E/M codes such as 99213 because they require audio and video. I have confirmed with Noridian and the recent HHS guidelines also confirm. Telephone only evaluations are billed with G2012 or 99441-99443.

  16. Ashlee says:

    Hello, I have a patient that called in with her daughter. The patient is unable to communicate, so the adult daughter speaks to the provider. Are we allowing this an a normal E/M visit as long as all elements are there to support the level?

  17. William Dacey says:

    In your answer to the question above about ‘leveling EM’ for Telehealth you said “CMS is revising their policy to specify that the office/outpatient E/M level selection for these services when furnished via telehealth can be based on medical decision making (MDM) or time, with time defined as all the time associated with the E/M on the day of the encounter; and to remove any requirements regarding documentation of history and or physical exam in the medical record” Can you direct us to that authority from CMS? Thank you…

  18. Anna Marunchenko says:

    Hello, If (for this public health emergency period) Medicare has relaxed documentation requirements for E&M codes to only require Medical Decision Making, could a brief telehealth visit for med refill be billed as 99211 or 99211? Or if audio only, a 99441, 5-10 min phone call?

  19. Renee Dustman says:

    Jennifer:
    Yes, bill the face-to-face office visit code with modifier 95 to ensure proper payment.

  20. Renee Dustman says:

    That’s taken from the interim final rule, page 141

  21. Himani says:

    What about 99441-99443? Should they be billed with a modifier? If so, 95 or GT?

  22. ALIYA ASAD says:

    we have been billing 99381-99395 to Simply Healthcare Insurance with place of service 02 but they are denying the codes as “Place of service not valid for CPT Code”. is this the correct denial? is there any way to get the payment?

  23. Renee Dustman says:

    Aliya, You should ask the payer how they would like you to bill those services. Those codes aren’t traditional telehealth codes so they may require the actual POS and modifier 95, like Medicare.

  24. Renee Dustman says:

    It depends on the payer. If it’s Medicare, append modifier 95, and the actual POS (not POS 02). Only distant site practitioners billing telehealth services under the critical access hospital Optional Payment Method II still use modifier GT.

  25. Kimberly L Pegues says:

    Hi. I know the initial and subsequent wellness visits are a covered service under telehealth but are there any guidelines to support not collecting the patients vital signs as they are required for this service?

  26. Lily Mayo says:

    For telehealth services, do we collect the copay prior to transfering the call to the doctor or can we bill the patient?

  27. Renee Dustman says:

    As per CMS-1744-IFC, E/M level selection may be based on MDM or time, and the requirement for documentation of a history and/or examination has been temporarily waived.
    Examination via telehealth is limited, but it is permissible for a provider to document pertinent observations such as skin color, skin lesions/rashes, quality of respiration and evidence of wheezing or dyspnea, vital signs as reported by the patient. When this is done, these factors may also contribute to the level of coding. When they aren’t done, they cannot be used for leveling.

  28. Ashley says:

    Inpatient telehealth consultation codes for CI or Medicaid , would you use the 99251 CPT code set with a modifier 95?

  29. Deeann Del Rio says:

    I have billed several 99441 and 99942 codes to Medicare and they have all been denied with code 96 Non covered services . When I look these codes up in the Medicare fee schedule there is no value. What was the effective date of Medicare’s decision to cover these codes? Do we have to bill with a 95 modifier ? I am billing with place of service 11

  30. R Best says:

    we are using the 99441-99443 for telephone evaluations, what rev code is being used with these codes?

  31. Sue says:

    Will Florida Medicare First Coast Service Options payf or an LCSW to do a 98966-98968 via telephone only?

  32. Renee Dustman says:

    Yes, you must include Modifier 95, effective for DOS March 6, 2020.

  33. Jennifer says:

    Physical Therapy (outpatient)
    If a preferred telehealth platform is NOT being used per carrier and the patients are incurring patient responsibility for those services (ERA is posted) do you believe they will waive this by May 17th?

  34. Renee Dustman says:

    “Will Florida Medicare First Coast Service Options pay for an LCSW to do a 98966-98968 via telephone only?”

    Codes 98966-98968 are eligible for payment during the current public health emergency per CMS’s Interim Rule. These codes are not on the telehealth code list so you would append Modifier 95 and the actual place of service code (not POS 02) during the public health emergency.

    The CMS document Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19 further explains that “these temporary changes will apply immediately across the entire U.S. healthcare system for the duration of the emergency declaration,” and that “all beneficiaries across the country can receive Medicare telehealth and other communications technology based services wherever they are located.”

    While this would suggest Medicare First Coast Service Options will pay for the service during the current emergency, you will need to verify that they are following Medicare’s interim ruling.

  35. Renee Dustman says:

    “Using the 99441-99443 for telephone evaluations, what rev code is being used with these codes?”

    The revenue code for telehealth services is 078X. However, we have yet to locate current guidance about whether it should be used with 99441-99443.

  36. Renee Dustman says:

    “Inpatient telehealth consultation codes for CI or Medicaid, would you use the 99251 CPT® code set with a modifier 95?”

    Code 99251 is not currently accepted by Medicaid as a telehealth service. Commercial payers should recognize this consult code with modifier 95 if furnished by telehealth. You will need to check with specific payers for their policy, however.

  37. Renee Dustman says:

    Jennifer: We’re not in a position to say.

  38. Lauren says:

    Does anyone know if you can do an AWV and office visit on the same dos for a telehealth visit? (as long as documentation supports the problem visit with the AWV)

  39. MG says:

    What CPT codes, Modifier and POS codes can be used when a provider does telemedicine/televisit for seniors living in Assisted living facilities or other patients in Skilled Nursing Facilities – either for initial patient visits or established patients?

  40. Bonnie Sarver says:

    When doing a Medicare Wellness visit G0438 or G0439, via Telemed can they be done by phone only, or does it have to be video?

  41. Renee Dustman says:

    “What CPT codes, Modifier and POS codes can be used when a provider does telemedicine/televisit for seniors living in Assisted living facilities or other patients in Skilled Nursing Facilities – either for initial patient visits or established patients?”

    Latest guidance is to report the procedure and POS codes as you would normally and append modifier 95 to those services rendered via telehealth.

  42. Renee Dustman says:

    audio-only is allowed per the telehealth code list, updated 4/30

  43. CA says:

    In regards to documentation requirements, specifically “You should also add a statement to the effect that the service was provided non-face-to-face, and document the patient’s location, the provider’s location, and the names and roles of anyone participating in the encounter.” We have not been documenting the patient and provider’s locations; is this a hard requirement or a best-practice suggestion? If a requirement, does anyone know where I can find documentation from CMS (or an alternative source) to that effect? None of what we’ve seen up to now has indicated it as a hard requirement, and I’d like to have back-up before I ask my providers to remember ANOTHER thing to add to their documentation. Thanks!

  44. Renee Dustman says:

    I’ll see if I can find where this guidance came from. Also note, in CMS-1744-IFC, CMS says, “In cases where it is medically contraindicated for the patient to leave the home, the medical record documentation for the patient must include information as to why the individual condition of the patient is such that leaving the home is medically contraindicated.”

  45. Perla says:

    Medicare is allowing to use home visits and reimbursement is higher vs. regular E/M codes. What is the difference for these two sets of codes when billing for telehealth visits?

  46. Kathy Maynard says:

    Renee since G0438 & G0439 can be done audio only, what modifier would we use? Modifier 95 includes both audio & video?

  47. Monica Rice says:

    Does anyone know if Medicade , Blue Cross or Commercial insurances are covering annual wellness exams via Telehealth? Thank you

  48. Renee Dustman says:

    Doesn’t matter. Still use modifier 95 and the POS the clinician would normally perform the service. CMS is overlooking the video requirement for these codes.

  49. Susie says:

    Can we bill an AWV (phone only) in addition to 99441, if it was due to separate issues?

  50. Renee Dustman says:

    Susie: Theoretically, yes, as long as the 99441 didn’t lead to the AWV or vice versa within 7 days before or after, you should be able to receive payment. This question is best posed to the payer, however.

  51. Renee Dustman says:

    Perla, My understanding it that you can only use the home visit codes if the patient is homebound. The doctor would have to document that the patient is unable to leave their home because of medical reasons.

  52. Renee Dustman says:

    You should be able to find that info in the Medicare Physician Schedule.

  53. Renee Dustman says:

    AAPC does not report on Medicaid or commercial insurance. We recommend you contact the payer.

  54. Renee Dustman says:

    Many payers do not have the system updates in place. The effective date is March 1. You will need to resubmit claims.

  55. Renee Dustman says:

    If the documentation supports the visit. Although only MDM or time needs to be documented, the other E/M components are expected to be delivered.

  56. Renee Dustman says:

    In this case, you would bill the service as you would have had it happened face to face and append modifier 95.

  57. Renee Dustman says:

    Yes, this is generally allowed.

  58. Renee Dustman says:

    Your payers are the authority on coverage, and each may have a different policy. Speak to each one, get a definitive answer, and create a chart for staff to follow.

  59. Renee Dustman says:

    Bill: This is on p. 141 in CMS-1744-IFC

  60. Renee Dustman says:

    During the PHE for COVID-19, all clinicians who are eligible to bill Medicare are permitted to perform telehealth codes.

  61. Cyndi A. says:

    Does anyone have documentation from CMS or another reputable source that states documentation must include the patient and the provider’s location?

  62. Renee Dustman says:

    Cyndi: It was in one of CMS’ communications, but I can’t find it now. In one of their FAQs, #28, they say “We expect the same level of documentation that wold ordinarily be provided if the services furnished via telehealth were conducted in person.” https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf
    They also say in the FAQ that medical necessity must be documented, and patient consent must be documented.

  63. Shirley Wong says:

    When billing for two E/M services under Telemedicine, should modifier 25 sequence first or modifier 95 sequence first? Thanks in advance!

  64. Renee Dustman says:

    I don’t know that it would matter, but it would be easier to ask your payer than to resubmit the claim if they deny it.

  65. Richard says:

    Hi, does the patient need to be present (in the video) in order to bill a telemed visit? For in-person visits, i.e. 99213, patient or family, is required to be present.

  66. Renee Dustman says:

    The code description says “Typically, 15 minutes are spent face-to-face with the patient and/or family.” If that is not the case, the provider needs to document why time wasn’t spent with the patient, or choose a different code that more accurately describes the service.

  67. Axis says:

    can you bill 99214 and G2023 – mod 25 together? The G2023 done for patients who do not have COVID symptoms but need to get tested.

  68. Renee Dustman says:

    Based on the description for G2023 Independent labs report this code when a trained laboratory technician collects a nasopharyngeal, oropharyngeal, sputum, or another type of specimen for the purpose of performing a laboratory test for the SARS–CoV–2 virus, I would say no. The exception may be if you are in a facility with a lab.

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