Cardiology Coding Alert

Critical care among new codes added to Medicare telehealth list to be covered during COVID-19 PHE.

During the novel coronavirus (COVID-19) public health emergency (PHE), Medicare has made significant updates to its telehealth rules to better facilitate healthcare for those impacted by the COVID-19 pandemic. To explain these telehealth changes, the Centers for Medicare & Medicaid Services (CMS) issued a series of press releases (March 17 and March 30), in addition to the Interim Final Rule published in the Federal Register on April 6 (https://www.cms.gov/files/document/covid-final-ifc.pdf).

“Due to COVID-19, all healthcare systems have been requested to cancel all elective procedures. This has had a huge impact on all specialties, especially cardiology,” says Christina Neighbors, MA, CPC, CCC, Coding Quality Auditor for Conifer Health Solutions, Coding Quality & Education Department, and member of AAPC’s Certified Cardiology Coder steering committee. “CMS has provided additional allowances to providers for telehealth. The providers may treat patients via video and/or audio, which allows the physician to treat patients in the safety of their own homes. The benefit of this is the patient, provider, and staff can minimize COVID-19 exposure. Telehealth also keeps the patients safe and healthy at home.”

For this two-part series, you will learn about the guidelines for Medicare telehealth visits. Then, in part two you can learn about the other types of virtual services, as defined by Medicare Part B.

Read on to make sure that you always submit clean claims for virtual visits in your cardiology practice.

Figure Out Medicare Telehealth Visits

FAQ 1: What are Medicare telehealth visits?

Answer: A Medicare Part B telehealth visit is designated for patient encounters that would typically occur in-person. Patients may communicate with a practitioner from a healthcare facility or from within their own home as a result of the COVID-19 exceptions.

For a visit to qualify as a Medicare telehealth visit, the patient must use “an interactive audio and video telecommunications system that permits real-time communication between the distant site and the patient at home,” according to CMS in its March 17 press release. Meeting the requirements for a telehealth service can most easily be achieved using a smartphone and an app. There are HIPAA-compliant apps that are integral to many EHRs, and there are standalone apps, such as Doxy and Chiron.

Don’t miss: The recent expansions of services and HIPAA waivers that have been provided allow practices to use communications such as FaceTime and Skype during the COVID-19 PHE.

Grasp Which Patients Can Receive Medicare Telehealth Visits

FAQ 2: Who can receive Medicare telehealth visits?

Answer: Usually, only established patients may receive Medicare telehealth visits. However, the Medicare 1135 Waiver allows telehealth visits for new patients “for claims submitted during this public health emergency,” according to the Medicare Telemedicine Health Care Provider Fact Sheet.

Lean on These Codes For Medicare Telehealth Visits

FAQ 3: How should I report Medicare telehealth visits?

Answer: CMS had an original list of services for a typical Medicare telehealth visit. Examples of codes on this original list included 99201-99215 (Office or other outpatient visit for the evaluation and management of a new/ established patient …), G0425-G0427 (Telehealth consultation, emergency department or initial inpatient …), and G0406-G0408 (Follow-up inpatient consultation … communicating with the patient via telehealth).

Important: Recently, the Interim Final Rule added more than 80 new services to be covered as Medicare telehealth visits on an interim basis during the COVID-19 PHE. You can find the entire list of covered telehealth services here: www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.

Take a look at some of the newly added interim codes: (Note: This is not an exhaustive list.)

• Emergency department visit codes 99281-99285
• Initial and subsequent observation and observation day management codes 99217; 99218 99220; 99224-99226; and 99234-99236
• Initial hospital care and hospital discharge day management codes 99221-99223 and 99238-99239
• Critical care codes 99291 and +99292
• Home visit codes 99341-99350

Follow Interim Rules for Leveling Telehealth E/M Services

FAQ 4: How should we level office/outpatient E/M visits when they are furnished via Medicare telehealth during this PHE?

Answer: On an interim basis during this COVID-19 PHE, CMS has revised its policy so now office/outpatient E/M level selection for office/outpatient E/M telehealth visits can be based on medical decision making (MDM) or time. Time is defined as all of the time associated with the E/M on the day of the encounter. The requirements regarding documentation of history and the physical exam have been removed.