Wiki Telehealth Billing

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From my understanding on March 23, 2020, they extended telephone encounters to be billable as E/M visits due to some beneficiaries not having a virtual (video) option along with the GT/95 modifier. I received this info from Humana but not sure if this is across the board for all insurances. I am combing thru the CMS website and don't find this information. Does anyone any insight about this policy change?


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I am wondering if anyone has any guidance or recommendation on billing virtual telecommunication visits?
How to bill (codes, modifiers, ect...)?
Payer reimbursement?
Any information would help!

Thanks in advance for any information!


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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.