CMS.gov posted new guidelines for TeleHealth during the COVID-19 crisis. They will not audit new or established pt. However, do I submit 99203 or do I use an established visit due to the fact that normally you cannot bill a new patient visit. Would this require a modifier since it also lists that GT is no longer necessary as long as POS is 02 would I use 95? How are we to bill new pt. visits to MCR?
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Wiki Telehealth Medicare new patient visits (due to crisis)
- Thread starter heathreg
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jhendrix08
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-It's my understanding that you can bill the same E/M code that you would bill for a face-to-face office visit; Medicare is reimbursing the same amount for Telehealth visits. You will change the POS to 2; and yes I understand a modifier is not required. A new patient visit is now listed as a billable code for Telehealth. If you need it, I can link a list of the approved codes. Let me know. I've done a lot of reading on this recently. 
Can you send the attachment you were referring to in the chat above. I work for an Urgent Care and we have never offered Telehealth visit before but with COVID19 we are now needing to implement this asap. I want to make sure we truly can bill CMS pts E&M visits. Do they have to established pts. Can we do this via a pt. portal or what requirements are there on recording the visit.
Here is my summary of what I've read. 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. Their fact sheet lists 99201-99215. 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. The amount of time is cumulative over 7 days. 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.
CMS fact sheet: https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet
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.
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. Their fact sheet lists 99201-99215. 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. The amount of time is cumulative over 7 days. 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.
CMS fact sheet: https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet
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.
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amelia77
Guest
I work in pain management and our providers are seeing New Patients under telehealth. Can you clarify for me that this is even allowed? We get a ton of referrals from neurosurgeons so our provider is wanting to continue to see these patients without having them come into the office. From what I'm reading it's not allowed, however, Medicare will not be doing an audit during this time of emergency.
I want to make sure that we are billing correctly. Also, it's my understanding that a phone call is not telehealth. We are doing these also under telehealth. How do I approach my provider to let him know this?
mimraapc
Contributor
We are a PCP office based in Florida. Can you please share any material showing that medicare do not require GT modifier anymore with the E/M codes for telehealth? I really appreciate your help and time. Thank you.
I think my previous post did answer these questions, but I realize this is new to almost everyone & changing rapidly.
1) Telehealth new patients. Typically not allowed, but Medicare states they are turning a blind eye. So while the official rule states no, they realize it will be done & have stated they will not pursue this. Medicare lists 99201-99215 as the telehealth E/M codes on their fact sheet. Commercial carriers may have different policies. Most seem to be following Medicare's lead.
2) TELEPHONE IS NOT TELEHEALTH. The definition of telehealth is listed in both the fact sheet https://www.cms.gov/Outreach-and-Ed...s/Downloads/Telehealth-Services-Text-Only.pdf and also now an MLN brochure https://www.cms.gov/Outreach-and-Ed...s/Downloads/Telehealth-Services-Text-Only.pdf. Both define telehealth as via interactive audio and video.
The latest MLN article about it specifies the GT is only used in very unusual circumstances. It does not apply to 99.5% of providers billing telehealth during the emergency. This was also clarified during NGS Medicare webinar call yesterday afternoon.
TELEHEALTH = interactive audio and video. POS 02. Medicare no modifier. Commercial typically modifier -95 unless otherwise advised.
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.
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