Medicare Telehealth Coding as of April 30
Healthcare providers are granted even more latitude for use of telehealth services during the COVID-19 public health emergency.
On a Friday, at month-end, the Centers for Medicare & Medicaid Services (CMS) kindly dropped another bomb on us: more temporary policy changes during the public health emergency for COVID-19. We may have this all sorted out just when the PHE ends.
When attending CMS’ “House Calls” on Tuesdays and Thursdays, it has been clear that additional guidance and information, beyond what is found in the April 6 Interim Final Rule, is necessary. During the calls, the answers to many questions have been that the CMS staff know that the issue is still open and they will get back to us.
CMS addresses many of the open issues from these calls, which center around non-physician providers and telehealth services, in an April 30 press release. The press release states that these changes have come from “requests from providers as well as by the Coronavirus Aid Relief and Economic Security Act, or CARES Act.”
There are multiple goals to the telehealth changes addressed in the April 30 press release. Addressed here is the third goal, which is to “increase access to telehealth for Medicare patients so they can get care from their physicians and other clinicians while staying safely at home.”
Telehealth Coverage Updates
- CMS is waiving limitations on the types of clinical practitioners who can furnish Medicare telehealth services for the duration of the COVID-19 PHE. Prior to this change, telehealth services were limited to doctors, nurse practitioners, physician assistants, and others who also qualified to furnish evaluation and management (E/M) services. Now, physical therapists, occupational therapists, and speech language pathologists can bill for telehealth.
Note: It does not state this in the press release, but please keep in mind that providers are still limited to providing services within the scope of their state license. State scope of practice overrides any payers’ rules. This is important for both maintenance of the providers’ licenses and malpractice coverage.
- Hospitals can bill for remote services provided by hospital-based providers to Medicare patients who are registered as hospital outpatients, including when the patient is in their home, when the home is serving as a temporary provider-based department of the hospital, which CMS refers to as Hospitals Without Walls. These services can include counseling and educational services and well as therapy services.
- Hospitals can bill as the originating site for telehealth furnished by hospital-based practitioners to Medicare patients registered as hospital outpatients, including when the patient is located at home (Hospital Without Walls). The press release does not state what the originating site code should be, but G0463 has been discussed during CMS Office Hours.
Note: The hospital is paid a facility fee (originating site fee), and they should use hospital outpatient POS 22 since that is where the service would have normally been provided if the PHE did not exist, along with the 95 modifier to indicate that the service was provided via telehealth.
- CMS added services that could be provided via audio-only telephone between patients and their doctors back on March 30, 2020. CMS is increasing the list of what services may be audio-only telephone to include many behavioral health and patient education services.
- The telehealth code list was updated on April 30 to add a column to the spreadsheet which indicates: “Can Audio-only Interaction Meet the Requirements?” If there is a “Yes” in that column, you may bill that code when the practitioner used audio-only telephone.
Note: The “Covered Telehealth Services for PHE for the COVID-19 pandemic” is located at: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.
Below is a snapshot of the spreadsheet. I have highlighted the new column (gray), which indicates if audio-only telephone interaction can be used. CPT® codes 97802, 97803, and 97804 allow for audio-only interaction. As you can see, there is no “Yes” in the highlighted column for 99201, 99202, and 99203. This means that an audio-video interaction must take place for office E/M services to be coded and billed to Medicare as a telehealth service.
- CMS is increasing the payment for telephone services (99441-99443) to better match payments for office visits. The payment rates will go from $14-$41 to about $46-$110. The payment rate change is retroactive to services performed on or after March 1, 2020.
- CMS has been adding to its list of covered telehealth services using its rulemaking process, but will now add new telehealth services on a sub-regulatory basis. They will consider requests from providers as they learn about utilization of telehealth services more broadly and update the telehealth code list, as necessary. Check this list often! (The link is above.)
- The CARES Act mandated that CMS expand telehealth services to rural health clinics and federally qualified health clinics (FQHCs). Now Medicare patients registered in these settings will have access to telehealth services from their home. CMS also issued an update on RHCs and FQHCs on April 30 during the PHE via MLN Matters article SE20016.
Because all of these changes have been published via a press release, these instructions are not as in-depth as in the rule making process. Expect CMS to refine the “how to” and clarify questions. One useful activity is to dial into the twice weekly “Office Hours” calls that CMS has on Tuesdays and Thursdays at 5 pm ET. Check your MLN publications and emails for the phone number and pass code to dial into the calls.
- COVID-19 Emergency Declaration Blanket Waivers & Flexibilities for Health Care Providers (PDF) UPDATED (4/30/20)
- Medicare and Medicaid IFC: Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency (CMS-5531 IFC) (PDF) (4/30/20)
- Tests for which Medicare Does Not Require a Practitioner Order During the PHE
- Home Health Agencies (PDF) UPDATED (4/30/20)
- Physicians and Other Practitioners (PDF) UPDATED (4/30/20)
- Ambulances (PDF) UPDATED (4/30/20)
- Hospitals (PDF) UPDATED (4/30/20)
- Teaching Hospitals, Teaching Physicians and Medical Residents (PDF) UPDATED (4/30/20)
- Long Term Care Facilities (Skilled Nursing Facilities and/or Nursing Facilities) (PDF) UPDATED (4/30/20)
- Hospices (PDF) UPDATED (4/30/20)
- Inpatient Rehabilitation Facilities (PDF) UPDATED (4/30/20)
- Long Term Care Hospitals & Extended Neoplastic Disease Care Hospitals (PDF) UPDATED (4/30/20)
- Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) (PDF) UPDATED (4/30/20)
- Laboratories (PDF) UPDATED (4/30/20)
- End Stage Renal Disease (ESRD) Facilities (PDF) UPDATED (4/30/20)
- Durable Medical Equipment (PDF) UPDATED (4/30/20)
- Medicare Advantage and Part D Plans (PDF) UPDATED (4/30/20)
- State Medicaid & Basic Health Programs (4/30/20)
- Medicare Shared Savings Program Participants (PDF) (4/30/20)
Questions can be sent to CMS regarding COVID-19 coding and billing by emailing them at: COVID-19@CMS.HHS.GOV.
Source: April 30 CMS Press Release