We have received many inquiries on the reporting of telehealth codes due to CMS reducing the restrictions on telehealth services. As of today, these reductions are available for the diagnosis and treatment of any conditions and/or diseases retroactive to March 6, 2020. While there has been communication from some commercial insurance carriers as to their reduction in restrictions also, as of this notification, it is unknown if they will follow CMS. HIS will keep you updated if new developments change the restrictions.
Medicare Telehealth Services
- Applicable to codes 99201-99215
- Providers must use an interactive audio and visual telecommunications system that permits real-time communication. These services must have a video component.
- Currently, CMS allows for use of telecommunications technology that have audio and video capabilities that are used for two-way, real-time interactive communication. For example, to the extent that many mobile computing devices have audio and video capabilities that may be used for two-way, real-time interactive communication they qualify as acceptable technology.
- The new waiver in Section 1135(b) of the Social Security Act explicitly allows the Secretary to authorize use of telephones that have audio and video capabilities for the furnishing of Medicare telehealth services during the COVID-19 PHE. In addition, effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency.
- Documentation requirements are the same as if the patient was being seen in person.
- Reimbursements will be the same as in-person office visits.
References:
CMS News: President Trump Expands Telehealth Benefits for Medicare Beneficiaries During COVID-19 Outbreak
Medicare Telemedicine Health Care Provider Fact Sheet https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet
Medicare Telehealth Frequently Asked Questions (FAQs) March 17, 2020
https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf
Other Medicare Services
The following services are not considered telehealth and have always been available for Medicare patients. Some commercial insurance carriers may reimburse for these also. These services are only available for established patients.
G2010– Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, 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.
- Patient generated still or video image
- Not within 7 days of office visit
- Does not result in an office visit in the next 24 hours or next available appointment
- Can only be reported if image is clear enough for review
- Review is performed and documented
- National average Medicare reimbursement $12.27
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
- Not within 7 days of office visit
- Does not result in an office visit in the next 24 hours or next available appointment
- Follow up needs to be performed by HIPAA compliant communication. Telephone, email, text, portal
- Summary of service needs to be documented
- National average Medicare reimbursement $14.80
Online Digital E/M Services 99421-99423
- Must be an established patient
- The service has to be initiated by the patient
- EHR portal
- Other digital application
- Includes evaluation, assessment, and management needs to be documented.
- Reported by total time spent in a 7-day period. The time needs to be documented.
- If another E/M service occurs in the 7-day period, these services are included in that service and are not billed separately.
99421- Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time
during the 7 days; 5-10 minutes
- National average Medicare reimbursement $15.52
99422- Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time
during the 7 days; 11-20 minutes
- National average Medicare reimbursement $31.04
99423- Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 21 or more minutes
- National average Medicare reimbursement $50.16
Telephone Services
These services are not covered by Medicare and most commercial carriers. This can be a self pay
service.
99441- Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian 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
99442- Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian 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; 11-20 minutes of medical discussion
99443- Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian 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; 21-30 minutes of medical discussion
Any questions or concerns please feel free to contact Lynn M. Anderanin, CPC, CPMA, CPC-I, CPPM, COSC