Telehealth

pdinapoli

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I work in a primary care physician office looking to limit patient interaction and primarily use phone or video capabilities. These services are entirely new and never billed prior to the national emergency. I have begun billing 99441-99443, 98966-98962 and G2012. I am trying to gain clarity on Medicare emergency rules giving patients access to telehealth. I am reading it as thought the physician can bill for telehealth if they use Facetime and has been treating patient for 3 years same condition? Any additional information or clarification on this topic would be greatly appreciated.
 

mitchellde

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Just remember for the codes you are using these must be services initiated by the patient and not a scheduled encounter. They are not telemedicine. Telemedicine uses regular office visit codes with the 02 POS and must be interactive audio and visual medium. The patient must be in a qualified originating site and not at home at least for Medicare, these can be prior scheduled encounters
 

pdinapoli

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Thank you, I am aware of the above. I'm looking for interpretation on some of these restrictions being lifted because of the national emergency. It is my understanding that the originating site restriction has been lifted and services can be rendered via video and audio in the patients home. Any clue?
 

mitchellde

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No i did not read that in any of the notices. What I saw was that they would consider paying for the telephone calls and the Skype calls made by the patients. Medicare typically does not reimburse those. I have not read any notice that lifted the originating site description for telehealth. Instead the notices I read only reinforced the telehealth definition vs the telephone calls and Skype calls definition, and indicated that in most Regions Medicare would reimburse for the phone and Skype calls as an interim measure but you are to check with your region first.
 

midnight1995

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Regarding the Telemedicine - I reviewed this from White House if I reading htis correctly they are waving the originating site - “We are providing $2.2 billion in public health funding for prevention, preparedness and response, including nearly a billion dollars specifically to alleviate the immense financial strain on state, local, tribal and territorial hospitals and health systems. To protect public health, the bill will allow Medicare providers to extend telemedicine services to seniors regardless of where they live, at an estimated cost of $500 million - does any one have the same readying on this
 

mitchellde

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Right now for telehealth the patient must live in a qualifying rural location, this announcement is waiving that but it does not address the originating site for the service. It does not say the patient can be at home at the time of the service. I would be careful in interpreting this to mean you can bill telehealth for a patient that is at home at the time of service. You can however use telephone and online digital evaluation and management codes
 

Arnkpc

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Regarding the Telemedicine - I reviewed this from White House if I reading htis correctly they are waving the originating site - “We are providing $2.2 billion in public health funding for prevention, preparedness and response, including nearly a billion dollars specifically to alleviate the immense financial strain on state, local, tribal and territorial hospitals and health systems. To protect public health, the bill will allow Medicare providers to extend telemedicine services to seniors regardless of where they live, at an estimated cost of $500 million - does any one have the same readying on this
Where is that information? Can you provide a link?
 
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Work in a pediatrician's office. We are also doing the same - limiting face to face visits and trying to do these via phone. Brand new place of work and they don't have any coding book on site. We have received information from our local medicaid office that we are ok to bill 99441-99443 and 98966-98962 but are unsure if we need to attach a 95 modifier. Also concerned about place of service as most of these people will be at home. Please advise where I can go to get these questions answered.
 

mitchellde

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No modifier,, those are phone visit and online such as Skype they are not telehealth you are really going to need a code book to assist you.. I suggest getting one from a bookstore such as a Barnes and Noble
 

Stefanie

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No i did not read that in any of the notices. What I saw was that they would consider paying for the telephone calls and the Skype calls made by the patients. Medicare typically does not reimburse those. I have not read any notice that lifted the originating site description for telehealth. Instead the notices I read only reinforced the telehealth definition vs the telephone calls and Skype calls definition, and indicated that in most Regions Medicare would reimburse for the phone and Skype calls as an interim measure but you are to check with your region first.



From this link:


EXPANSION OF TELEHEALTH WITH 1135 WAIVER: Under this new waiver, Medicare can pay for office, hospital, and other visits furnished via telehealth across the country and including in patient’s places of residence starting March 6, 2020.

While they must generally travel to or be located in certain types of originating sites such as a physician’s office, skilled nursing facility or hospital for the visit, effective for services starting March 6, 2020 and for the duration of the COVID-19 Public Health Emergency, Medicare will make payment for Medicare telehealth services furnished to beneficiaries in any healthcare facility and in their home.
 

dmrbilling

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If a patient is limited and does not have a computer or smartphone to have a visual visit with the provider. Billing for a telephone visit instead of a telemedicine would be appropriate. Has anyone been paid by Medicare for telephone calls? Since the elderly are the ones that cannot make it out to the clinic, Medicare would be the most common payer we would bill telephone calls with. Any feedback?
 

vcar

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I work for a facility owned multi-specialty practice with multiple locations. Normal office services are billed POS 11 under each individual location. In order to use POS 02 would we need to do multiple builds in our practice management software to reflect each office location or can we have IT build 1 location for the services possibly using the facility address? I think it would need to be each individual office. But our IT team is overwhelmed so I though I'd ask.
Thanks!
 

C.Campbell

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I work for a small ortho practice- My physicians are wanting to call the patients on the schedule to offer telemedicine vs. face to face.
My understanding is telemedicine should be patient initiated. So basically the patient should be the one to call for an appt. we explain we aren't doing face to face but can provide telehealth calls. They can either agree or not agree correct?

They physician stand point is how do they know we can do it if we don't call to offer, and feel this should be ok since CMS has relaxed the guidelines.

Any clarification would be greatly appreciated so I can explain to my Drs. or at least be confident we are doing this the correct way.

Thanks!
 
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Does anyone have any insight with commercial payers regarding telephone calls only? The emergency policy updates from Aenta, Florida Blue, Cigna, Humana, and UHC are all Covid specific only addressing "virtual check-ins" of 5-10 mins as covered and copays wavied.. there is no clarity for normal telephone consults only, non related to CoVid. Should i bill for the normal telephone code set 99441-99443/98966-98968?
 
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So for a visual visit with a patient in their home would you bill the office visit (99212-99215) with POS (11) of POS (02)? And for a phone call, 99441-99443, is the POS (11)?
 

Ccdgea08

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So for a visual visit with a patient in their home would you bill the office visit (99212-99215) with POS (11) of POS (02)? And for a phone call, 99441-99443, is the POS (11)?

POS 2 for telehealth GT modifier for medicare and 95 for commercial showing it was a telehealth visit. you do not need the 99441 - 99443 codes. the only insurance covering these is AETNA.
 

Ccdgea08

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Just remember for the codes you are using these must be services initiated by the patient and not a scheduled encounter. They are not telemedicine. Telemedicine uses regular office visit codes with the 02 POS and must be interactive audio and visual medium. The patient must be in a qualified originating site and not at home at least for Medicare, these can be prior scheduled encounters
They have lifted the restrictions patient can be home. You can not see the patient in the office 24 hours before or 7 days after the telehealth call or you can not bill telehealth. Per medicare change you can bill for any diagnosis by telehealth due to the pandemic.
 

Ccdgea08

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Does anyone have any insight with commercial payers regarding telephone calls only? The emergency policy updates from Aenta, Florida Blue, Cigna, Humana, and UHC are all Covid specific only addressing "virtual check-ins" of 5-10 mins as covered and copays wavied.. there is no clarity for normal telephone consults only, non related to CoVid. Should i bill for the normal telephone code set 99441-99443/98966-98968?

As far as I know Aetna is the only one that will cover the 99441-99443/98966-98968 codes. They all want some sort of video capable phone. UHC is following medicare guidelines where you use a smart phone or video capable phone for office visits and use regular em codes with pos 2 and GT modifier for medicare and 95 modifier for commercial. virtual check ins I think need a photo or prerecorded video from the patient to qualify.
 

Ccdgea08

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I work for a facility owned multi-specialty practice with multiple locations. Normal office services are billed POS 11 under each individual location. In order to use POS 02 would we need to do multiple builds in our practice management software to reflect each office location or can we have IT build 1 location for the services possibly using the facility address? I think it would need to be each individual office. But our IT team is overwhelmed so I though I'd ask.
Thanks!
you would build in POS 2 telehealth. you do not need a specific facility attached to the POS
 

Ccdgea08

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From this link:


EXPANSION OF TELEHEALTH WITH 1135 WAIVER: Under this new waiver, Medicare can pay for office, hospital, and other visits furnished via telehealth across the country and including in patient’s places of residence starting March 6, 2020.

While they must generally travel to or be located in certain types of originating sites such as a physician’s office, skilled nursing facility or hospital for the visit, effective for services starting March 6, 2020 and for the duration of the COVID-19 Public Health Emergency, Medicare will make payment for Medicare telehealth services furnished to beneficiaries in any healthcare facility and in their home.
Regarding the Telemedicine - I reviewed this from White House if I reading htis correctly they are waving the originating site - “We are providing $2.2 billion in public health funding for prevention, preparedness and response, including nearly a billion dollars specifically to alleviate the immense financial strain on state, local, tribal and territorial hospitals and health systems. To protect public health, the bill will allow Medicare providers to extend telemedicine services to seniors regardless of where they live, at an estimated cost of $500 million - does any one have the same readying on this
I work in a primary care physician office looking to limit patient interaction and primarily use phone or video capabilities. These services are entirely new and never billed prior to the national emergency. I have begun billing 99441-99443, 98966-98962 and G2012. I am trying to gain clarity on Medicare emergency rules giving patients access to telehealth. I am reading it as thought the physician can bill for telehealth if they use Facetime and has been treating patient for 3 years same condition? Any additional information or clarification on this topic would be greatly appreciated.

Medicare you must bill regular em codes 99201-99215 with GT modifier POS 2 telehealth. united health is following medicare guidelines. They can use a smart phone or computer and use any kind of video calling such as face time, skype, video calling. The patient must be an established medicare patient or if seeing the same physician and just went from bcbs to medicare and has not seen the doctor since getting medicare. Medicare will still pay.
 

Ccdgea08

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Regarding the Telemedicine - I reviewed this from White House if I reading htis correctly they are waving the originating site - “We are providing $2.2 billion in public health funding for prevention, preparedness and response, including nearly a billion dollars specifically to alleviate the immense financial strain on state, local, tribal and territorial hospitals and health systems. To protect public health, the bill will allow Medicare providers to extend telemedicine services to seniors regardless of where they live, at an estimated cost of $500 million - does any one have the same readying on this

yes they have
 
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Does anyone know if INITIAL nursing home visits can be billed using telemedicine? I am not really finding anything on it. The list that CMS has as approved codes do not have them listed but that was updated in November and they are not on the list. CPT codes 99304-99306.
 

lisaneese

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Is anyone billing regular phone visits if they cannot do "telehealth" with a smart phone or other capabilities. I understand that they are not covered by Medicare but what options do we have when phone calls are the only way to communicate with the patient? Also, what about phone calls that last longer than 30 minutes?
 

arochier

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The facility I work with is new at this with the national emergency. So I am just trying to make sure we do it correctly. So do we bill the Telemedicine codes if the patient initiates the call and the provider or nurse talks to them to determine if they really need to present or just treats them over the phone. Or should be billing the regular office visit codes with 95 modifier for commercial payers (that's really all we bill), and POS 02? Also looking for some insight on what the documentation should look like.
Thanks
 
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My understanding is telemedicine should be patient initiated. So basically the patient should be the one to call for an appt. we explain we aren't doing face to face but can provide telehealth calls. They can either agree or not agree correct?
To bill the telephone call codes, the patient must initiate the call. Say they were seen 10 days ago and it's not getting better (whatever they were seen for). Doc talks to them for 10 minutes, changes their med, says call me if anything changes. THAT is the type of phone call that is 99441-99443.

The telehealth services that you are describing are entirely different, and are the ones billed with regular codes and POS 02, and do NOT have to be initiated by the patient.
 
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Medicare's fact sheet does a good job of comparing the different distant-site services: https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet
Don't miss out on code G2012 (Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, 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) for your Medicare patients who call in to speak with the doctor about minor concerns in lieu of a face-to-face visit. This service can be delivered by phone (no video component required), patient portal, email, etc.

Also, bill telemedicine modifier 95 and place of service 02 only for audiovisual communications. If not familiar, the CPT description of modifier 95 is helpful.

For online digital services, advanced practice professionals (eg, NP, PA, CNS) bill the online digital services E/M codes. Other professionals, like nutritionists and therapists, bill the 989 codes in the medicine section or the Medicare G codes.

Even when the distant-site service is offered in lieu of a scheduled face-to-face appointment, be sure to document the patient's acknowledgement of financial responsibility and consent to the phone, email, or telehealth service. Patients will likely think anything other than a face-to-face visit in the office is free.

Hope that helps.
Cindy
 
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The Texas Governor released the following. But I am still confused. i am not sure is he is calling telephone only encounters Telemedicine and therefore billable as Telemedicine? if you keep reading, the article starts talking about making sure that the documentation fits the description of the CPT code, the method of delivery and if the insurance carrier needs a modifier to make sure we meet that guideline.

So are telephone only evaluations billable with the an office visit code (99201-99215)? With modifiers 95 or GT?

Thank you for your time!!!!
 

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mitchellde

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The GT modifer is not used for Medicare unless you are specifically designated to use the modifer and it is based on geograph. They created the 02POS as a better way to designate telehealth from face to face. Commercial payers use the 95. You do not use the 02 POS for the phone call or e-visits because those codes already specify what they are used for.
 

twdevore

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Our facility is using 99211-99215 with a GT modifier and POS 02. I'm assuming that the document will still need to have the appropriate number of elements to support the level billed. Notes will still require appropriate number of ROS elements, MDM and documented time. All the rules regarding these codes revolve around them being done face to face. I've been searching for something that explains documentation requirements when they are not done face to face and am coming up empty handed...Any have anything?
 

csperoni

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Our facility is using 99211-99215 with a GT modifier and POS 02. I'm assuming that the document will still need to have the appropriate number of elements to support the level billed. Notes will still require appropriate number of ROS elements, MDM and documented time. All the rules regarding these codes revolve around them being done face to face. I've been searching for something that explains documentation requirements when they are not done face to face and am coming up empty handed...Any have anything?
Since Debra is probably tired of saying the same thing in multiple postings, I'll answer and summarize. 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 an 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.

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.

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.
 

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Shuggins1

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Does anyone know if INITIAL nursing home visits can be billed using telemedicine? I am not really finding anything on it. The list that CMS has as approved codes do not have them listed but that was updated in November and they are not on the list. CPT codes 99304-99306.
Did anyone every answer this. I am looking for the same information. We were going to go with the regular code and add the 02 POS. We still are not positive
 

lennysara

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Since Debra is probably tired of saying the same thing in multiple postings, I'll answer and summarize. 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 an 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.
 

LAKEENYA

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Since Debra is probably tired of saying the same thing in multiple postings, I'll answer and summarize. 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 an 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.
CSperoni, thank you for the detailed explanation. Maybe you can answer another question. How do you handle the coding when the provider starts the encounter with the patient via telemedicine and due to some technical issues they are unable to complete it and finish the encounter via telephone only?
 

rlmiller

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Can a provider be at home and code and bill telehealth visits with remote access to the patients chart? I cannot find anything that states the provider MUST be in their office to bill telehealth visits under the 1135 Waiver.
 

csperoni

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CSperoni, thank you for the detailed explanation. Maybe you can answer another question. How do you handle the coding when the provider starts the encounter with the patient via telemedicine and due to some technical issues they are unable to complete it and finish the encounter via telephone only?
Someone else asked this in a different thread. I offered my unofficial opinion of billing telehealth if most of the encounter took place via video and telephone encounter if it didn't work at all, or minimally. I would rather err on the side of caution in this unusual circumstance.
 

csperoni

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Can a provider be at home and code and bill telehealth visits with remote access to the patients chart? I cannot find anything that states the provider MUST be in their office to bill telehealth visits under the 1135 Waiver.
I don't know if this is addressed in any of the official CMS guidance, but this exact question was posed during NGS Medicare telehealth webinar yesterday afternoon. The provider may be at home, or another location. Still bill POS 02.

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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csperoni

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Does a visual physical exam count? My provider asked this.
MOST of the organ systems cannot just be examined visually. You could maybe get constitutional, psych, possibly limited skin. Via video only, you cannot examine eyes, ENT, respiratory, cardiovascular, GI, GU, lymphatic, musculoskeletal or neurologic. To the limited extent that an exam via video only is possible, you can count those if the documentation meets the requirements of 1995 or 1997.
In our practice, I have advised the providers that we will code based on time since basically 100% of time is counseling.
 

trarut

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::snipped:: 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. ::snipped::
Will you provide further insight into what you are documenting for location?
 
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I am fairly new to coding. I work for group of physicians and telehealth is new for us.

If the patient is coming to the parking lot of the doctors office, a staff member goes out and checks their temp, has the patient to call the office and the call is transferred to the nurse to triage and the call is transferred to the physician and he/she completes the exam. Is this considered telehealth or are these consider a phone call? The doctor never has a visual of the patient.
 

Kristen Bensel

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I found this today on the AMA website.
https://www.ama-assn.org/practice-management/digital/ama-quick-guide-telemedicine-practice

It looks like the restriction that telephone encounters are not able to be billed as E/M has been lifted temporarily-which is amazing. (I found that information first on the United Healthcare website from the UHC link at the bottom of this page.) But I found this particular link very helpful with the visual aids!

https://www.ama-assn.org/system/files/2020-03/covid-19-coding-advice.pdf

Hope this is helpful for everyone.
 

vgodoy

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We are doing telehealth visit but the providers want to start doing new patients appointments. Can the Medical Assistants call the patient collect the CC and social and medication history before the Provider starts the Audio / Video telehalth visit? I cant find documentation saying no but MA's in California are not permitted to do Assesments.
 
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