Wiki Billing Telephone Services for Providing Test Results over the Telephone

[bbernal]

I am interested in anyone's thoughts regarding whether billing telephone services ( 99441, 99442, 99443 ) to give test results is acceptable. Thank you.

 

[StacyGalloway]

99441: Telephone evaluation and management service provided by a physician 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. If you decide to bill for these services, the following criteria should be met:• Service is personally performed and reported only for established patients.• The call must be initiated by an established patient.• If the patient is a minor, the episode of care must be initiated by a guardian/parent.• These are time-based codes. The length of the telephone call must be documented, in addition to the nature of the service and other pertinent information, in the medical record.• If the telephone service relates to and takes place within a postoperative period, the service is considered part of the procedure and not separately reportable.• The telephone encounter cannot be related to an E/M service performed and reported by the physician or qualified nonphysician health care professional within the previous seven(7) days.• If the telephone call ends with a decision to see the patient within 24 hours or the next available urgent appointment, the telephone encounter is considered part of the preservice work of the subsequent E/M service, procedure and visit.• Telephone services cannot be reported with Care Plan Oversight CPT Codes: 99339-99340and 99374-99380, nor Anticoagulation Management CPT Codes: 99363 – 99364.• Providers must meet every part of the CPT definition and there must be documentation in the medical record to support the services.• These services are a non-covered service by Medicare and delivery of an Advance Beneficiary Notice of Noncoverage (ABN) is not required.

 

[jkyles]

I am interested in anyone's thoughts regarding whether billing telephone services ( 99441, 99442, 99443 ) to give test results is acceptable. Thank you.

Hi there, even though Medicare will continue to cover telephone visits in 2024, practices should keep in mind that even when appropriate there is a patient co-pay for the phone call. But here are some other things a practice should consider.
1. The call must be initiated by the patient and they must talk to a QHP or physician. When the physician or QHP calls the patient, that's automatically a service you can't bill. Requiring patients to call the practice to get their test results in order to generate a billable charge would be hard to defend if a MAC challenges the charge.
1a. How often would the test results call fall outside of the 7-day post-visit period?
1b. How often would those calls meet the five minute threshold?
2. How would your practice treat patients who don't have a telephone visit benefit?
3. What was your billing pattern before 2020? Did your practice require all patients to come to the practice to get their test results and bill an E/M visit? If not, what's the justification for billing for the telephone E/M visit?

 

[cgaston]

This is from the CodingIntel website:

“Ordering a test is included in the category of test result(s) and the review of the test result is part of the encounter and not a subsequent encounter.”
And, from the CPT Assistant, (AMA publication) November, 2020, page 5: “It is assumed that the physician or other QHP would review the results of the test ordered; therefore, the physician or other QHP would not receive dual credit toward MDM for service-level selection for both ordering and reviewing the test.”

The AMA is consistent in this instruction. If you order a diagnostic test, say a CBC at a patient visit, reviewing the results that day, or, a day later, or at the subsequent visit, it is part of the order. When the patient returns to the office two weeks later, you do not get credit for reviewing the CBC results that you ordered. Count the data for the test once, at the encounter when it was ordered."


Whether it is true or not, it could be perceived that the provider is withholding test results until the patient pays for an additional visit which could be seen as unethical. Reviewing results with a patient does not adequately support medical necessity for charging a separate E&M visit. If the results are normal, there really is no medically supported reason to charge for a separate visit. However, If the results are abnormal and medical decision making regarding the abnormality has been documented, the visit would support medical necessity for a separate E&M visit.

 

[jkyles]

The normal vs. abnormal test results also brings up another patient care issue: Even if the practice can bill for the call, it may not be appropriate to deliver the test results by phone.