Wiki Telehealth complexities ???

flowergrl

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A doc recently started billing telehealth office e/m. So far I have figured out the Place of Service requirements and dates when telehealth use has been extended (thru 2024). A few questions, and hopefully someone can post relevant sources to back up rules.

1. Can a provider schedule a future audio-video or audio-only telephone call visit with a patient? Example - patient is in office for follow up. Provider completes the visit and says "Schedule telehealth visit follow up in 1 month". So the scheduler puts the patient on the schedule for a telehealth visit in 1 month. I would think audio-video visit would be coded with regular office visit 99202-99215 codes, pos 11 and modifier 95 until end of 2023 then with 02/10 until end of 2024. However, provider wants to bill 99441-99443 for the audio-only. --- Isn't 99441-99443 only for "patient initiated" visits? As in, the patient comes up with a problem and contacts the office to discuss?
The provider does document "Patient initiated contact for today's visit, called from home." I'm thinking the provider is saying "patient initiated" means the patient starts the visit by calling into the office. So is this audio-only even billable?

2. Provider schedules patient for telehealth visit 10 days after office visit for review of labs results ordered and drawn at the office visit, discussion about patient status and recommendations based on the lab results. This is sometimes audio only and sometimes audio-video based on the patient's level of video access/knowledge. (Again, the patient initiates the call for the visit that day by calling in to the office to start the visit). But it was previously scheduled. What codes can be used? Is Audio-Video still billable for review of labs/advise/medical planning or does it require more medical necessity than that? And again, is 99441-99443 applicable for audio-only if it's scheduled?

What are the documentation requirements for doing telehealth visits? I've spent HOURS online researching and gotten basically nowhere on specifics.
I'm thinking...
1. must document patient consent for telehealth visit.
2. must document why visit is telehealth and not in-person?
3. must document time spent with provider only
4. must document medical necessity for the visit, can't be just to report lab results and advise to continue plan?
 
Hi there, have you asked the doctor why they want to bill those visits as telephone rather than office visits via telehealth?
1. If the only reason the patient is calling is because the doctor told them to, that's not a patient initiated call.
2. For an audio-only call, this seems to be the same thing as the earlier example. An office visit by telehealth could be OK, IF it is a medically necessary visit and that's the provider's normal pattern for visits. That is, a provider who has historically had patients come in for a follow up visit to review test results (and the documentation supports medical necessity, etc) will be less likely to attract a payer's attention than one who is suddenly billing a bunch of extra visits by telehealth.

For the rest of your questions regarding an office visit via telehealth - you'll need to review individual payer policies and state law for special telehealth consent requirements. For Medicare I haven't seen a requirement to document why the visit is via telehealth rather than in person. The documentation and coding for any visit must meet the requirements set out for that code.
 
I do recall seeing an article from NAMAS regarding AUDIO ONLY 99441-99443 should now indicate why the service wasn't telehealth (audio/video) or in person.
"Audio only codes 99441-99443 will be with payment parity of 99212-99214 with the -95 modifier through 12/31/2024, however, documentation of why the patient could not be on an audio and video visit or attend an in-person encounter must be entered."
 
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