Consent for Communication Technology-Based Services (CTBS)

• Both CPT and CMS have developed codes for non-face-to-face communication-based technology services in recent years.
• In addition to care management services, these include interprofessional consults, remote monitoring and on-line digital E/M services, using the functions of a HIPAA compliant communication system, without a face-to-face service with the patient
• In the 2020 Physician Fee Schedule Final Rule, CMS clarified the type of patient consent that is required to perform (and bill for) these services

In 2019, CMS finalized payment for non-face-to-face, technology-based services, and noted that verbal consent would be required, and that this was a similar requirement as for care management services. These codes include the 2019 HCPCS codes G2010 and G2012 , interprofessional consult codes 99451, 99452, and 99446—99449. All of these services have beneficiary cost sharing associated with them, and CMS wants the patient informed of the cost to them before the services are provided.

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