Recorded at HEALTHCON 2023 in Nashville, TN
The panel at AAPC discussed significant updates to the coding system for telemedicine and artificial intelligence (AI) in healthcare. They highlighted the rapid adoption of digital medicine during the pandemic, which increased telehealth spending from 0.1% to 17% of Medicare expenditures.
The introduction of new CPT® codes aims to enhance the integration of AI and telemedicine services, addressing the needs of underserved populations and improving health equity. The panel emphasized the importance of clear coding definitions and the ongoing efforts to support physicians in utilizing these technologies effectively. Future discussions will focus on maintaining the momentum of telemedicine and ensuring fair payment for services.
Where AI already shows up in care
Wearables support clinical decisions, e.g., Apple Watch ECG with FDA-cleared AFib history features.
Virtual reality helps with pain management and procedure anxiety.
Radiology tools overlay analyses on images to assist interpretation.
Digital pathology enables remote slide review and workflow at scale.
AI can also enhance education and presentations with autogenerated visuals.
Telemedicine before the pandemic
Tight rules meant low adoption and access.
Key Medicare constraints included rural/originating site limits, no payment for audio-only, and established-patient requirements for RPM.
Result: telemedicine spend was about 0.1% of Medicare prior to 2020.
What shifted during and after the pandemic
Temporary waivers removed barriers, triggering a surge in use and then a stable “new normal.”
Telehealth peaked near 17% of Medicare fee-schedule spend at the height of shutdowns, then settled well above pre-pandemic levels.
Many beneficiaries relied on telehealth; some received only telehealth during key quarters.
Equity impacts you should know
Audio-only visits improved access for marginalized groups (older adults, publicly insured patients, Spanish-speaking patients, and Black patients).
Takeaway: keeping audio-only options matters for equity and continuity.
RPM and RTM at a glance (what they are and how they’re coded)
Remote physiologic monitoring (RPM) tracks physiologic data to manage disease (E/M section; device must meet FDA’s “medical device” definition).
Remote therapeutic monitoring (RTM) tracks non-physiologic data (e.g., therapy adherence/response) and opens billing beyond E/M specialties (Medicine section).
Each family includes setup/education, device supply (RPM: general; RTM: respiratory, musculoskeletal, CBT), and 20-minute treatment management codes.
Devices require at least 16 days of patient-generated data per 30-day period.
RPM treatment time may be furnished by clinical staff under supervision; RTM treatment time must be by a physician or other QHP.
Modifiers for telehealth
Modifier 95 identifies two-way audio-video services (see Appendix P for eligible codes).
Modifier 93 identifies audio-only services (see Appendix T for eligible codes).
Use the correct modifier to reflect the tech actually used.
The digital medicine taxonomy (Appendix R)
Provides a common language for digital services:
Physician-to-patient (synchronous and asynchronous).
Physician-to-physician (synchronous and asynchronous).
Patient monitoring (RPM/RTM).
Digital diagnostics.
It’s an educational map, updated as services evolve.
The AI taxonomy (Appendix S)
Defines how to describe AI in CPT by physician experience, not algorithm brand names.
Three categories clarify physician vs. machine roles:
Assistive: Detects clinically relevant findings; physician performs analysis and interpretation.
Augmentative: Analyzes/quantifies data on a clinically meaningful scale; physician interprets and concludes.
Autonomous: Interprets data and generates clinically meaningful conclusions; levels 1–3 vary in how actions are initiated and how physicians intervene.
Goal: clear descriptors and fair valuation for both human work and machine support.
Recent and upcoming CPT developments to watch
New examples align with the AI taxonomy:
Augmentative: Coronary fractional flow reserve derived from coronary CTA (category I, effective Jan 1, 2024).
Assistive: Algorithmic electrocardiogram (category III pair).
Autonomous: Remote retinal imaging for diabetic retinopathy (already listed; terminology now aligned).
Telemedicine E/M overhaul proposed for 2025:
Seventeen new, more granular telemedicine office visit codes (new/established, AV and audio-only) to replace broad “modifier 95 on office visits” approach.
Intent: support fair, differentiated payment and reduce blunt “all telehealth pays X%” policies.
AMA advocacy priorities post-PHE
Lift rural/originating site restrictions and allow the patient’s location as an originating site.
Support fair and equitable payment across in-person, audio-video, and audio-only when clinically appropriate.
Advance telehealth to address longstanding inequities through practical access (including audio-only).
Practical documentation and billing tips highlighted
For time-based reporting, document total time on the date of the encounter; add clinically relevant context to support medical necessity.
Avoid rigid “same time every visit” templates; ensure listed reviews (labs, notes, imaging) are actually in the record and used in decision making.
Count data review once unless there’s a clear clinical reason to re-review and compare.
For RPM/RTM, confirm device meets FDA medical-device definition and that interactive communication occurred.
Use the proper audio-only or audio-video modifier and align with payer policy.
Q&A highlights
RPM 99454 timing: There’s awareness of confusion between 30-day vs. calendar month; harmonization across families is under discussion.
RTM for CBT: RTM can support CBT when there’s true monitoring with data returned to the clinician and treatment management is documented.
Midpoint rule: Use general CPT time guidance unless specific section guidelines (e.g., minimums or family rules) supersede it.
Telephone codes: Expect transition toward new audio-only telemedicine E/M codes rather than legacy “telephone” language.
Who can bill interprofessional consults: CPT is scope-of-practice agnostic; payer and placement (Medicine vs. E/M) determine who may report.
“AI used” modifier: Not planned; AI relationships are captured in code descriptors via the AI taxonomy to support accurate valuation.
Useful AMA resources to share with your teams
Appendix R (digital medicine taxonomy) and Appendix S (AI taxonomy) for shared definitions.
Appendix P and Appendix T for telehealth-eligible codes by modifier.
AMA Ed Hub education (including E/M 2021 modules).
CPT summary of panel actions (posted 30 days after each meeting) for early visibility into future changes.
Bottom line for coding and compliance leaders
Learn the taxonomies now; they’re the Rosetta stone for new digital and AI services.
Keep audio-only workflows and documentation strong—it matters for equity and payment.
Align RPM/RTM operations to the 16-day rule, FDA device criteria, interactive touchpoints, and who can furnish time.
Prepare for 2025 telemedicine E/M code specificity and payer differentiation.
Partner with clinicians and IT so tools fit clinical workflow and support clean claims.