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June 8, 2023

Coding Telehealth Visits

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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.

  • There are two new POS codes for coding telehealth visits, but don’t start using them for Medicare.
  • 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.”

This policy is confirmed in the 2023  Physician Fee Schedule Final Rule.

“As such, we are finalizing that we will continue to allow for payment be made for Medicare telehealth services at the place of service for telehealth services that ordinarily would have been paid under the PFS, if the services were furnished in-person, through the latter of the end of the of CY 2023 or the end of the calendar year in which the PHE ends. For those services furnished in a facility as an originating site, POS 02 may be used, and the corresponding facility fee can be billed, per pre-PHE policy, beginning the 152nd day after the end of the PHE.” page 197

Continue to use the place of service in which the service would have been provided until Dec. 31, 2023.  CMS has extended this policy, which allows services that would have been performed in the office to be paid at the non-facility (higher) rate until Dec. 31, 2023.

One MAC, NGS posted a question about this, which is linked below.

https://www.ngsmedicare.com/web/ngs/news-article-details?lob=96664&state=97224&rgion=93623&selectedArticleId=3794814

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

Coding telehealth visits

  • 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

  • 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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Last revised May 17, 2023 - Betsy Nicoletti
Tags: telehealth

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Audit tool for Modifier 25

Reasonable coders and practitioners can and do disagree about when a separate E/M service is warranted on the day of a minor procedure. This audit tool for modifier 25 will help determine if a separate E/M service should be reported. Using it consistently will help practices be reliable in their determinations and provide support in payer audits. Sign up for our monthly newsletter to download the reference sheet.

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2023 E/M guidelines for hospital, nursing facility, home and residence services | Webinar

Effective January 1, 2023, the AMA has revised the definitions and guidelines for hospital and other E/M services, including ED visits, nursing facility services, home services, and domiciliary care codes. Also, coding for prolonged care services gets another overhaul with revised codes and guidelines. Watch this webinar about all these changes.

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Our mission is to provide up-to-date, simplified, citation driven resources that empower our members to gain confidence and authority in their coding role.

In 1988, CodingIntel.com founder Betsy Nicoletti started a Medical Services Organization for a rural hospital, supporting physician practice. She has been a self-employed consultant since 1998. She estimates that in the last 20 years her audience members number over 28,400 at in person events and webinars. She has had 2,500 meetings with clinical providers and reviewed over 43,000 medical notes. She knows what questions need answers and developed this resource to answer those questions. For more about Betsy visit www.betsynicoletti.com.

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