EM Coding Alert

Telehealth:

Don’t Get Lax on Telehealth Rules

Remember: There are different rules for synchronous audio/visual meetings versus telephone calls.

Your practice may have let virtual check-ins slip by the wayside a bit as you’ve scrambled to accommodate the many facets of telehealth services. Still, as the pandemic surges on, virtual check-ins are still a crucial aspect of E/M services for practices.

Save yourself a lot of struggle by using this expert advice on untangling the current and previous CPT® and HCPCS Level II codes that your practice may use for physician (and other provider) virtual check-ins.

Remember: Technically, a virtual check-in includes any brief patient communication with a provider via a number of communication technology modalities. In addition to telephone calls, the service may include asynchronous (staggered response) exchanges through video or image.

Pinpoint the CPT® Codes

Even before the pandemic, you had the following CPT® codes for telephone-based E/M services:

  • 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)
  • 99442 (…11-20 minutes of medical discussion)
  • 99443 (… 21-30 minutes of medical discussion)

Reminder: In March of 2020, CMS announced that it would temporarily extend coverage for 99441-99443 as virtual check-in service codes for the duration of the Public Health Emergency (PHE) due to Covid-19. The PHE has been renewed multiple times and is still in effect at press time.

The 2021 Medicare Physician Fee Schedule (MPFS) national non-facility payment amount (conversion factor [CF] 34.8931) for 99441, 99442, and 99443 respectively is $56.88, $92.82, and $131.55.

Coder’s note: The 99441-99443 code descriptors clearly indicate what is known as the eight-day exclusion rule. The rule indicates that you may not use the virtual check-in codes for a service that originates from a related E/M service within the prior seven days, or leads to a separate E/M service within the next 24 hours (or soonest available appointment thereafter). “However, keep in mind that there’s at least one Medicare Administrative Contractor, NGSMedicare, that has eliminated those exclusion dates,” says Barbara J. Cobuzzi, MBA, CPC, COC, CPC-P, CPC-I, CENTC, CPCO, of CRN Healthcare in Tinton Falls, New Jersey. “Check with your local MAC to confirm that the eight-day exclusion period still applies,” Cobuzzi advises.

Consider HCPCS Level II Codes

Prior to the pandemic, coders also had a HCPCS Level II code that is very similar to 99441, which is 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). “The main distinction between 99441 and G2012 is that the CPT® code is limited to a telephone call, while you can use G2012 to describe other communication methods for virtual check-ins,” says Terri Brame Joy, MBA, CPC, COC, CGSC, CPC-I, billing specialty subject matter expert at Kareo in Irvine, California.