Very helpful! Thank you !Here's my summary. Everything below is only for providers that may bill E/M services (physicians, nurse practitioners, physician assistants, etc.)
1) Telehealth (which is interactive audio and video, not just telephone) is billed with E/M codes. POS 02. Commercial insurance modifier 95. Medicare no modifier UNLESS you are in a geographic area that was always allowed to bill telehealth, then GT as you would have prior.
Telehealth is typically only for established patients, but CMS has stated they will not look into whether or not you actually saw the patient prior - kind of a don't ask, don't tell policy.
It may be a scheduled visit.
2) Documentation of history, exam & MDM should be done as usual, realizing that exam cannot really be performed. You MIGHT be able to get constitutional (general appearance/vitals) and/or psychiatric (mood, judgment, etc). IF > 50% of visit is counseling, then you may bill based on time, just like for an in person office visit. Again, if billing based on time, that must be documented as well.
A TELEPHONE call is NOT TELEHEALTH. Telephone call must be patient initiated (you may inform pt of the service, but you can't start cold calling your patients and then bill your discussion). Must be established patient. Not originating from a visit in previous 7 days, or resulting in an upcoming appointment at soonest available. Not a scheduled visit. POS 11. Medicare use G2012. Commercial use 99441-99443.
There are also codes 99421-99423 for encounters taking place via your EMR's patient portal. We will not be using those, so I haven't really researched those.
For both telehealth and telephone encounters, you should inform the patient that the discussion is a billable encounter & document their verbal consent in the note. For telehealth you should document the location of the patient, and the location of the provider and of course something noting that the visit took place via interactive audio and video. For telephone, I do not recall seeing any requirement to document patient or provider location, but it certainly can't hurt in case I missed it.
While CMS has specifically stated they will cover these expanded services during the emergency, there is no such guarantee from commercial carriers. Many major carriers have come out with a policy that telehealth and telephone encounters will be covered, but this is not universal.
UPDATE ON 04/02/2020 TO ORIGINAL POST, AS GUIDANCE FROM CMS HAS CHANGED
As of 03/31/2020, CMS states for telehealth, "report the POS code that would have been reported had the service been furnished in person." with modifier -95 to designate it was telehealth. This way, you will get full reimbursement for nonfacility location, instead of reduced facility rate with POS 02.
Medicare will also now reimburse 99441-99443.
Guidance about POS/modifiers page 14-15. Guidance about 99441-99443 starts at bottom of 126.
This is CMS guidance only, and you should check with your commercial carriers about their rules.
Services must be conducted by a physician or other qualified health care professional who can independently report evaluation and management (E/M) services.Can an RN bill "incident to" an MD for the G2012 - like they can a 99211?
Does anyone have any info on how to reflect the orginating site on a claim? I know we should change the POS to 2 but I don't understand how to add the orginating site or where to add it on the claim form (1500 or UB04).