General Surgery Coding Alert

Distinguish G-codes from 99441-99443.

While you may have focused on telehealth services during the pandemic, virtual check-ins have gotten less attention but remain a constant and integral part of general surgery practice E/M services as the Public Health Emergency (PHE) has extended into 2021.

Let our experts untangle the 2021 and older CPT^® and HCPCS Level II codes that you might use for physician and other provider virtual check-in services, focusing on synchronous audio exchanges via telephone.

Refresher: 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.

Look for CPT^® Codes and Pay

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.

Don’t Ignore 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, Calif.

The Centers for Medicare & Medicaid Services (CMS) introduced the following virtual check-in code in the MPFS 2021 final rule that understandably got some coders confused:

• G2252 (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; 11-20 minutes of medical discussion)

As CMS puts it, this is essentially an indented code to G2012 (… 5-10 minutes of medical discussion) and is eligible for Medicare Part B (and other eligible commercial payer) reporting.

Pay: Compared to the telephone CPT^® codes, the MPFS national non-facility payment amount (conversion factor [CF] 34.8931) for G2012 and G2252 is $14.66 and $26.87, respectively.

What to Do?

The pay difference has left many coders asking, under what circumstances, if any, should you report G2012 and G2252 for eligible clinical virtual check-in services by telephone instead of the CPT^® codes?

Fortunately, the answer is as straightforward as it seems while the PHE is ongoing. Until CMS announces coverage of 99441-99443 has ceased, practices should be reporting those codes for all eligible (Medicare Part B and otherwise) telephone-based virtual check-in services.

For virtual check-ins by other asynchronous technology exchanges, such as secure patient portal queries and responses, you’ll need to rely on the G-codes.

Don’t miss: You can’t use any of these codes for services provided by someone who is not a physician or other provider who is ineligible to report E/M services. In those cases, you may turn to this code that CMS adds in 2021: G2251 (Brief communication technology-based service, e.g. virtual check-in, by a qualified health care professional who cannot report evaluation and management services… 5-10 minutes of clinical discussion).

Final tip: “CMS notes that there are several modifiers you should consider for your telehealth claims,” advises Carol Pohlig, BSN, RN, CPC, ACS, senior coding and education specialist at the Hospital of the University of Pennsylvania. But you don’t have to worry about those when your surgeon provides an E/M service to a patient on the phone, because the rules for telehealth modifier application do not apply to virtual check-in services.