Medicare “Audio-Only” Telehealth Services

• CMS issued multiple waivers and two interim final rules to support health care organizations and patients during the public health emergency
• Medicare requires real-time, audio and visual communication for most telehealth services, such as office visits and hospital services
• The April 30 revised telehealth list has a column “Can Audio-only Interaction Meet the Requirements” and some codes are indicated as “yes”

It’s old news that CMS has made major changes to its telehealth policy since March of 2020. But, one bit of news that hasn’t gotten as much press is that there are some services that there are now codes on CMS’s list of telehealth services that do not require audio and video communication equipment, but can be performed via audio only. Download the list to see for yourself which services these are.

These rules are temporary, during the time of the public health emergency. CMS has not indicated that these are permanent changes. This is a summary of the services that may be performed using phone only, and does not include all of the services or codes, so be sure to look at the excel sheet.

Behavioral Health Services

90791, 90792, 90832, 90833, 90834, 90836, 90837, 90838, 90839, 90840, 90845, 90846, 90847, 90853, 90875
This long list of service includes the psychiatric diagnostic interview, individual, family and group psychotherapy, psychotherapy for patients in crisis and the add-on code for interactive complexity. For Medicare patients, these services may now be provided with audio only phone calls. You can watch a short video about this here.

When a psychiatrist, psychiatric nurse practitioner or psychiatric physician assistant provides an E/M service for medication management and also provides psychotherapy on the same calendar day, the practitioner uses add-on codes 90833, 90836 and 90838. These three are added to the phone list. However, the established patient visit codes 99201—99215 with which they are more frequently used are not on the phone only list.

There are a large group of codes in the behavioral health medicine section that may be provided via phone only. These include developmental/behavioral screening, psychological/neuropsychological testing, testing evaluation services, test administration and scoring, health behavior assessment and intervention.

Telephone Calls 99441—99443

It makes sense that codes defined as telephone codes may be billed for audio only phone calls. The bigger news is that CMS increased the fee for these codes on April 30, 2020, retroactive to March. You can read more detail here. It isn’t clear if all MACs are re-processing these claims, or if the group needs to re-submit each one.

Individual and Group Medical Nutritional Services, 97802, 97803, 97804

These medical nutrition therapy codes are time-based codes provided to individuals or groups by nutrition professionals.

Face-to-Face Prolonged Services Codes 99354, 99355, 99356, 99357

The face-to-face prolonged care codes are added as phone only services. Keep in mind that these codes are most often used with office and hospital services that may not be billed via phone only, but still require audio and visual, real-time communication. These codes can also be reported with psychotherapy codes 90837 and 90847 which are on the phone only list. If the base code is not on the list, then the add-on prolonged services code cannot be performed by phone only.

Advanced Care Planning Codes 99497, 99498

These time-based codes for discussion with the patient and/or family member or surrogate, may be done via telephone only. Sometimes, they are the only service done on a day, but sometimes they are done in addition to another E/M service. If that other E/M service is a Medicare wellness visit, (G0438, G0439), that works, because the wellness visits can also be done with phone only equipment.

The Initial and Subsequent Annual Wellness Visit Code G0438, G0439

The initial and subsequent wellness visit codes may be done via phone only. The Welcome to Medicare/Initial Preventive Physical Exam service, G0402, may not be done via telehealth, either with audio/visual or phone only.

Screening HCPCS Codes

There are a list of screening HCPCS codes that may be done via the phone.

This is brief highlight of services that CMS says may be done via telehealth, without seeing the patient on a smart phone or on a computer camera. CMS released this list on April 30, and it is in effect during the time that the Secretary of Health and Human Services has declared a public health emergency. For these Medicare services, use the place of service where the service would have been performed, if done in person. Use modifier 95 on the CPT or HCPCS code.

---