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Medical coding resources for physicians and their staff. CodingIntel was founded by consultant and coding expert Betsy Nicoletti.

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Is it or isn’t it a telehealth service?

  • Many payers and practices use the broad term telehealth to describe services that are not done face-to-face with a patient
  • CMs describes telehealth services as non-face-to-face services that are on its telehealth list
  • During the public health emergency, CMS has temporarily eased the rules related to telehealth

The list of telehealth services is found in two places: CMS’s list of telehealth services and CPT’s list of CPT codes that could be reported via telehealth, in Appendix P of the CPT book. Both CMS and CPT defined telehealth as using a real-time, interactive audio and video communication system. CPT defined modifier 95 as “synchronous telemedicine service rendered via a real-time audio and visual telecommunications system.”  CMS’s list includes HCPCS codes.

And, prior to the public health emergency, Medicare only covered telehealth services in medically underserved areas, and required that the patient go to a local medical facility (originating site) to receive telehealth services. Telehealth from home wasn’t covered. That changed with a release of waivers in mid-March, and a new rule published 3/30/2020, making the changes retroactive to early March.

Refer to Telemedicine in the time of COVID-19 FAQ for additional information

Communication-based technology services (CBTS)—not telehealth

CMS began paying for services that used communication technology, but didn’t meet the criteria of telehealth. The patient wasn’t required to be in an underserved area and there was no requirement for real-time audio and visual communication. These included the brief virtual check-in HCPCS codes G2010 and G2012, and on-line digital E/M, 99421—99423. These are not on the telehealth list, are not considered to be telehealth services and do not require modifier 95. The don’t meet the definition of modifier 95, in the first paragraph of this article.

April 30, CMS updates the telehealth list again, and again in August of 2020

The old CMS telehealth list had two columns: code and description.

The March 30 telehealth list had three columns: code, description and a status column with this notation on some rows “Temporary Addition for the PHE for the COVID-19 Pandemic.”

The latest telehealth list has five columns: code, description, status and two new columns. One is “Can audio-only interactions meet requirements?” If so, there is a yes on that row. The fifth column is titled “Medicare payment limitations,” and there are a few rows in which the service is noted to be non-covered or bundled.

Services provided by audio-only interactions, that is the telephone!

In the Interim Final Rule with Comment (IFC) published on 4/30/2020, CMS stated it would increase the fees for telephone only services 99441—99443 to match the payment for 99212—99214. They added those codes to the telehealth list, and indicated that “yes” they could be performed via telephone only. That makes sense, since they are telephone calls.

The impact of this for practices is immense. When a patient didn’t have access to a smart phone or computer with a camera, practices were restricted to using the phone codes, which had very low reimbursement. Now, practices can use the phone codes and be paid the same rates as for established patient visits. 99201—99215 still require real time, audio and visual communication.

This is enormously helpful for established patients. For new patients, a clinician can use the telephone call codes, but the new reimbursement rate for phone only follows 99212—99214. If it is possible to use audio/visual communication for new patients, the reimbursement is higher.

New patients, established patients and level of service

CMS has stated that for office and other outpatient visit codes 99201—99215, a practitioner could select a code based on time or medical decision making. During the time of the public health emergency, no specific level of history or exam is required. That is a help for both new and established patient visits, and is similar to the coming new E/M CPT rules for 2021, for codes 99202—99215.

  • Use medical decision making, as currently defined

Or

  • Use total time spent, including face-to-face and non-face-to-face time. The visit does not need to be dominated by counseling. CMS had released different time thresholds for these visits in the March 30 rule, but in the April 30 rule, CMS said that we should use CPT typical times. CMS said they heard it was confusing to have two sets of time.

Of course, in 2021 documentation for codes 99202–99215 may be selected based on the total time on the date of service or medical decision making, not just telehealth services.

The chart below can be downloaded for quick reference

Medicare covered telemedicine services Audio only telemedicine services Communications-based-technology services CPT list of telemedicine services
Where do you find them? CMS updated list 10/14/2020 CMS updated list Not in a single place: G2010, G2012, 99421–99423 Appendix P of the CPT book
Communication requirements Real-time interactive, audio and visual Phone only Phone,  HIPAA compliant portal or messaging system According the the definition of modifier 95, synchronous communication system
Place of service, Medicare CMS says to use the POS where the service would have been furnished, if face-to-face, not POS 02 Use the place of service where the service would have taken place Use the place of service where the service would have taken place
Place of service, commercial insurers Each payer has its own rules Each payer has its own rules Use the place of service where the service would have taken place
Modifier, Medicare Medicare uses modifier-95 Codes 99441–99443 are added to the telehealth list, so use modifier 95 Do not use modifier 95. These are not on the telehealth list, and are not considered to be telehealth services
Modifier, commercial Most want modifier 95 but each payer has its own rules Each payer has its own rules Each payer has its own rules

Last revised January 31, 2022 - Betsy Nicoletti
Tags: telehealth

Wondering about the rules for HCC coding?

Wondering what the rules are for HCC coding, and where you can find them? This video answers your questions. The topic is important to medical practices because risk-adjusted diagnosis coding is part of Medicare Advantage contracts, many commercial contracts and Accountable Care Organizations (ACOs). Sign up for our monthly newsletter to download the whitepaper and watch the video.

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Our mission is to provide accurate, comprehensive, up-to-date coding information, allowing medical practices to increase revenue, decrease coding denials and reduce compliance risk. That's what coding knowledge can do.

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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