Coding Telehealth Visits

Coding telehealth visits changes faster than the weather here in New England. The resources on the site relate to Medicare policy and CPT codes and rules. Unfortunately, they don’t address individual commercial payer policies.

• Place of service codes for telehealth changed 1-1-2022, with an effective date of April 1, 2022.  These are listed below.
• Congress passed a law 12/20/2020 that allows behavioral health services to continue to be billed via telehealth after the end of the public health emergency.
• After the PHE ends, CMS continues to state that it does not have the statutory authority to pay for telehealth for patients in their homes unless Congress passes a law allowing it.

POS 02: Telehealth Provided Other than in Patient’s Home

Description: The location where health services and health related services are provided or received, through telecommunication technology. Patient is not located in their home when receiving health services or health related services through telecommunication technology.  (Effective January 1, 2017) (Description change effective January 1, 2022, and applicable for Medicare April 1, 2022.)

POS 10: Telehealth Provided in Patient’s Home

Description: The location where health services and health related services are provided or received, through telecommunication technology. Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology. (This code is effective January 1, 2022, and available to Medicare April 1, 2022.)

See CMS’s MedLearn Matters article describing the new POS code. It seems to indicate we shouldn’t use it!  Here is what they say:

“Medicare hasn’t identified a need for new POS code 10. Our MACs will instruct their providers to continue to use the Medicare billing instructions for Telehealth claims in Pub. 100-04, Medicare Claims Processing Manual, Chapter 12, Section 190.”

And, here is a link to the Family Practice Management journal article that describes the policies of two other payers.

Telehealth articles

• Telemedicine and COVID-19 FAQ
• Telemedicine in RHCs and FQHCs
• Is it or isn’t it a telehealth service
• Telemedicine | Webinar
• Payment for telephone calls
• Overview of Medicare telehealth services
• Interprofessional Internet Consultations
• CPT® codes (99421-99423) – and payment for – online digital evaluation and management (E/M) services
• Virtual communication: two new HCPCS codes G2010 and G2012
• Should we begin using the new CPT modifier -93
• Modifier 95
• Modifier CS
• Medicare changes telehealth rules, again

Telehealth source documents you can download

• Coding and reimbursement during the COVID-19 pandemic
• CMS list of telehealth
• AMA coding advice
• CMS interim rule – March 30, 2020
• CMS interim rule – April 30, 2020
• CMS enrollment COVID-19PEHotline
• Aledade guide to getting started with telehealth

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