Wiki Telephone encounter performed remotely

[crhunt78]

I have a provider performing telephone encounters remotely (provider is not in the office). Are telephone calls outside the office billable? I can't find anything from CMS and documentation in the chart does not indicate why the provider is not in the office or where they are while performing the service. The note just states the provider is "remote."

Does anyone have any information or documentation regarding these types of encounters?

Thanks in advance!

 

[jkyles]

Hi there, short answer: Yes you can bill a telephone E/M visit if the provider is not in the office.

From Medicare's point of view the provider's location doesn't matter so long as they are in the U.S. and they follow the rules for telephone E/M visits, including documenting their time.

Personally (and this is just an opinion), I think it would be best practices for providers to give a general idea of where they are (home/hotel in whatever state) just to make it clear they were in the U.S. and that it was feasible that they were able to provide the service.

 

[CBLENNIE]

I'm take a bit of an exception to @jkyles statement:

From Medicare's point of view the provider's location doesn't matter so long as they are in the U.S. and they follow the rules for telephone E/M visits, including documenting their time.

Because during the PHE CMS issued many waivers regarding providers enrollment in Medicare which can be found in document titled Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19, locations from which providers were allowed to render services, as well as state licensure. Some of these ended with the end of the PHE on 05/11/23. I would recommend reviewing pages 14-16, specifically at the following sections:

Practitioner Locations (page 14)
Provider Enrollment (page 14)
Reporting Home Address (page 16)
State Licensure (page 16)

So, there are still in fact certain requirements on where a provider can render audio only E&M services. The most important is going to probably be related to the provider's license and whether a state requires the provider to be licensed in their state to provider services. Which is separate from the fact that CMS will continue to accept claims for providers who are practicing outside the state of their enrollment with CMS.