CodingIntel

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

Telemedicine and COVID-19 FAQ

Updated: May 15, 2020

Read the article about modifier CS and cost sharing here

Medicare telehealth changes, released March 30, 2020, update for April 30, 2020 rule

  • Telephone codes were added to the list of services that can be billed via telehealth, and the rates for codes 99441–99443 were increased, to match the rates for 99212–99214
  • Office visit codes must still use two-way audio and visual, real time interactive technologies, but the payment rates for audio only codes (99441–99443) were increased
  • CMS added to the list of services that can be provided via telehealth to include additional hospital services, home visits, and domiciliary services
  • Inpatient neonatal and pediatric critical care and intensive care codes may be performed via telehealth
  • Additional services that are temporary additions to the services that may be performed via telehealth include care planning for patients with cognitive impairment, psychological and neuropsychological testing, physical therapy and occupational therapy and occupational therapy. The blanket waivers were updated at the end of April and physical therapists, occupational therapists and speech-language pathologists are now on the list of clinicians who can bill telehealth
  • Subsequent inpatient telehealth may be performed daily, without the prior limit of once every three days
  • See the full list here.
  • The April 30, 2020 list of telehealth services include some that may be reported using audio equipment only (download the list, two bullets down)
  • In order to bill office visits or any of the services that are not indicated as video only, on the list above, you must have interactive, real-time audio visual with the patient.

Hospital outpatient departments, provider based clinics

The April 30, 2020 rule states that a facility fee can be billed by hospital outpatient departments and provider based clinics. Use Q3014.

Place of service and modifier

On March 30, CMS released an interim rule with other changes.

First, all of these changes are effective March 1, 2020. CMS is changing the place of service for claims. Do not use POS 02 for CMS telehealth claims, use the place of service that would have been used if the patient had been seen face-to-face.

This means, if it is an office visit, you will be paid the higher, non-facility rate, not the facility rate. This is about $20 difference for office visits billed with POS 11. CMS now says to use modifier 95 on the claim. If billing in an outpatient department, use place of service 19 or 22. Use the place of service that would have been used.

Selecting a level of service

When CMS released the rule on 3/30/2020, they added a section titled, “W. Level Selection for Office/Outpatient E/M Visits when Furnished Via Medicare Telehealth.”  Pp 135-137

The brief section starts by discussing the upcoming changes in 2021 for codes 99202–99215, in which a practitioner can select a level of service based on total time for the day or MDM. The time spent includes non-face-to-face time that the practitioner spends and does not need to be dominated by counseling.

New, as of 4/30/2020 Using time

In their March rule, CMS released different times for selecting CPT codes for 99201–99215. It was very confusing. The end of April rule (and please, no end of May rule) said they heard we were confused, and to use CPT times.

CMS is allowing on an interim basis that we apply these rules to office/outpatient visits performed via telehealth during the time of the public health emergency. Specifically, they are removing any requirement for history and/or physical exam.  A clinician can use MDM or time to select the code, with time defined as “all of the time associated with the E/M on the day of the encounter.” They are using the existing time guidelines. They are keeping the current definitions of MDM, not the revised set that will be implemented in 2021.

  • For 99201–99215 provided via telehealth (real time, interactive audio/visual) a practitioner does not need to use the level of history or exam to select the service.
  • Use total time that the practitioner (not staff) spends on that day, whether or not counseling dominates the visit, or
  • Use MDM as currently defined.

April 7, 2020, MedLearn Matters email, modifier CS

CMS sent a MedLearn Matters email, that said that there would be no cost-sharing for COVID-19 testing, or for services related to the testing. It is retroactive to March 18, and extends until the end of the public health emergency. Append modifier CS to those claims. Claims already submitted will need to be re-processed. I’ve reproduced the article here.

Not defined as telehealth

On-line digital E/M (99421–99423 and G2061–G2063), virtual check in (G2010, G2012) and remote monitoring are not considered telehealth services. Do not use POS 02 or modifier 95 with these.

New! Telephone codes (99441–99443) are now defined as telehealth services. That article is updated.

Medicare telehealth visits are for office, hospital visits and other services allowed via Medicare’s existing policy for telehealth services.  There is a full list of these in the article on Medicare telehealth. Under the new regulations, to bill office visits and other approved telehealth services:

  • The provider must use an interactive, real-time audio and video telecommunication system in order to bill office visit codes 99201–99215.  If the patient does not have access to a smart phone or computer, do not bill office visit codes.
  • HIPAA privacy rules waived: may use FaceTime, Skype, Messenger video chat, Google hang out video
  • May not use applications that are front facing, such as facebook live, twitch or TikTok
  • CMS instructs groups to notify the patient that third party platforms may have privacy risk
  • Practitioners who may bill for telehealth include physicians, advanced practice registered nurses, physician assistants, CRNAs, clinical psychologists, clinical social workers, registered dietitians and nutrition professionals.  The rule released on 3/30/2020 adds therapy codes to the list, and the April 30 rule added physical therapists, occupational therapists, and speech-language pathologists.
  • Visits are paid at the same rate as in person visits.
  • The provider may waive the co-pay/deductible but is not required to do so.
  • On 3/30/202o, CMS said you are not required to use POS 02, but should use the place of service that would have been used if the patient was seen face-to-face.  This means, the office visit services will be paid at the higher, non-facility rate, not the lower, facility rate.
  • Now, CMS wants modifier 95 on the claim form.
  • On March 30, CMS added additional CPT codes that may be billed via telehealth. These are described at the start of this article, and the link to the download for the full list.
  • Virtual communication (phone calls, virtual check in codes G2010 and G2012, and digital E/M are not considered telehealth. Information about those services is below. Do not use place of service 02 for those services.  These are not considered to be telehealth services.
  • Remote monitoring services are covered, as well, are also not considered telehealth and do not require place of service 02.

On-site visits via video or through a window–report as telehealth?

CMS’s FAQ from 4/9/20 said that if the physician/NPP and the patient are located in the same facility, but not in the same room, and are communicating via telecommunication, these do not need to be reported as telehealth. Use the codes that describe the in person communication. (COVID-19 Interim Final Rule FAQs)

Supervision

CMS said in their 3/30/20 rule that direct supervision could be provided via audio/visual, real time communication.

RHCs and FQHCs

The CARES Act opened up payment for E/M services in these locations, but rules haven’t been issued yet. I believe RHCs and FQHCs will bill with E/M services, (not revenue codes) with an effective date  March 27, the date the CARES Act was signed. I will update this as soon as CMS releases further information.

RHCs and FQHCs may bill G0071, payment for communication technology-based services for 5 minutes or more of a virtual (non-face-to-face) communication between an RHC or FQHC practitioner and RHC or FQHC patient, or 5 minutes or more of remote evaluation of recorded video and/or image by an RHC or FQHC practitioner, occurring in lieu of an office visit; (RHC or FQHC only). The updated rate is $24.76.

CMS finally released instructions about FQHC and RHC billing.   There is a link to the MedLearn matters document at the article.

https://codingintel.com/telemedicine-in-rhcs-and-fqhcs/

Payment for phone calls

  • CMS will pay for phone calls using codes 99441—99443, and 98966—98968
  • The rates for 99441–99443 were increased to match the rates for 99212-99214. For full details, see the CodingIntel article on phone calls.
  • CMS stated in their 3/30/2020 rule that these codes may be used for new and established patient visits during the public health emergency
  • Physicians, nurse practitioners, and physician assistants should use codes 99441—99443
  • Other qualified health care professionals who may bill Medicare for their services, such as registered dieticians, social workers, speech language pathologists and physical and occupational therapists should use codes 98966—98968
  • These are telehealth services.

Real-time audio visual equipment is not required for G2012, G2010 or 99421—99423 because those are not considered telehealth services. The requirements for those are described in the article on telehealth, and in separate entries on CodingIntel.com. Links are listed later in this article.

Per the CPT definition, phone call codes 99441—99443 and 98966—98968 are services initiated by the patient (CMS did not discuss if this requirement was waived or not). They may not be provided if they are in follow-up for a visit within the past 7 days, or if they result in a visit in the next 24 hours, or next available appointment.   While 99441–99443 were added to the telehealth list and the rates increased, the same is not true for 98966–98968.

Physicians, nurse practitioners, clinical nurse specialists, certified nurse midwives and physician assistants use these codes:

99441  Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent or guardian not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion

99442              11-20 minutes of medical discussion

99443              21-30 minutes of medical discussion

Registered dieticians, social workers, speech language pathologists and physical and occupational therapists use these codes

98966  Telephone evaluation and management service by a qualified nonphysician health care professional to an established patient, parent or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an evaluation and management service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion

98967              11-20 minutes of medical discussion

98968              21-30 minutes of medical discussion

Code Description Non- Facility rate
99441 Telephone call 5-10 minutes $46.13
99442 Telephone call 11-20 minutes $76.04
99443 Telephone call 21-30 minutes $110.28
98966 Telephone call 5-10 minutes $13.32
98967 Telephone call 11-20 minutes $26.64
98968 Telephone call 21-30 minutes $39.60

 

New resources

 

Virtual check-ins (some payers are these, not office visits)

CMS is still paying for their HCPCS codes G2012 and G2010 You know what I think about these codes. Too little money for the effort to do and document. But, these don’t require real time audio/video, the way office visits do.  CMS stated in their 3/30/2020 rule that G2012 may be billed for both new and established patients during the public health emergency period.

Virtual communication: two new HCPCS codes G2010 and G2012

On-line digital E/M (some payers paying these, not office visits)

CMS began paying for these in 2020. These aren’t office visits via audio/video, but are more complex and convoluted to do and document. But, they were mentioned in CMS’s rules, and so I’m including them.

CPT® codes (99421-99423) – and payment for – online digital evaluation and management (E/M) services

Interprofessional consults (may be useful in the hospital setting)

These are not officially part of telehealth, but some groups are using them now in the hospital, so that fewer physicians see each patient in the hospital. They allow a consultant to do a time-based chart review and provide a verbal and written report back to the requesting clinician without seeing the patient.

Interprofessional Internet Consultations

Telehealth place of service and modifier for Commercial Payers

The place of service for telemedicine is 02.

CPT ® added modifier 95 to the CPT book in 2017. Medicare now requires it for telehealth, and many commercial payers do, as well. Experienced coders, billers, and administrators know that it is too much to hope that all of the payers will want claims to be submitted in the same way.

Modifier -95 Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications System: Synchronous telemedicine service is defined as a real-time interaction between a physician or other qualified health care professional and a patient who is located at a distant site from the physician or other qualified health care professional.

The totality of the communication of information exchanged between the physician or other qualified health care professional and the patient during the course of the synchronous telemedicine service must be of an amount and nature that would be sufficient to meet the key components and/or requirements of the same service when rendered via a face-to-face interaction.

Modifier 95 may only be appended to the services listed in Appendix P in the CPT book or on the list of CMS telehealth services, referenced at the start of this article. Appendix P is the list of CPT codes for services that are typically performed face-to-face, but may be rendered via a real-time (synchronous) interactive audio and video telecommunications system.

What about diagnosis coding?

Beginning April 1, there is a new ICD-10 code U07.1, 2019-nCoV acute respiratory disease.

I also heard on the news that insurances wouldn’t charge patients a co-pay for treating this illness. Is that true?

Yes, see the article on modifier CS.

Check back for updates.

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Comments

  1. Betsy, I am having a hard time finding the information around telephone calls down to the specific CPT codes. The new CMS list for Telehealth does not include these CPT codes. Can you provide a reference?

    Thank you
    Melody

  2. Betsy-Thanks for all your excellent up-to-date guidance. I saw that CMS added ED E/M codes to the list of approved Telehealth codes. ED providers are still not able to bill for a video/audio evaluation when patient and provider are both in ER, but in different rooms. Is that correct? The patient would have to call in from home to bill Telehealth, is that correct?
    CMS FAQ #15:
    Q: Should on-site visits conducted via video or through a window in the clinic suite be reported as telehealth services?
    A: Services should only be reported as telehealth services when the individual physician or professional providing the telehealth service is not at the same location as the beneficiary

    CMS:
    All beneficiaries across the country can receive Telehealth… wherever they are located.
    https://www.cms.gov/files/document/covid-19-physicians-and-practitioners.pdf

    • Thank you for reminding me about the FAQ. I’ve been trying to remember where I saw that. The quote above isn’t in the document you are linking to, but was from March 17, 2020, Medicare Telehealth Frequently Asked Questions, March 17, 2020. I haven’t seen it updated. When CMS says “across the country wherever they are located” I think that refers to removing the geographic restrictions.

      Here is the link to that:. If that link doesn’t work, put in a google search: “Medicare Telehealth Frequently Asked Questions (FAQs) March 17, 2020 and it should come right up for you.
      FAQ from CMS

        • After looking again at the rule, (thanks Elizabeth Woodcock) I think that a physician can do telehealth in the hospital, if the patient is in the room and the physician is outside of the room, using two way real time interactive audio/video.

        • CMS has updated the FAQ in regards to on-site video services. Question #9, page 15

          https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf

          …If the beneficiary and the physician or practitioner furnishing the service are in the same institutional setting but are utilizing telecommunications technology to furnish the service due to exposure risks, the practitioner would not need to report this service as telehealth and should instead report whatever code described the in-person service furnished.

          • Thank you for pointing that out. It’s good to have clarification form CMS. I notice they don’t say, “two way, interactive A/V” just telecommunications technology.

  4. Good afternoon
    do you have a link to support the statement regarding billing for telehealth services to CMS with POS 11 and modifier 95 instead of POS 02 and no modifier?
    Thank you!

  5. Can you please clarify. Your updated article states in order to bill office visits or any of the services mentioned in the bullets above, or on the full list referenced above you must have interactive, real-time audio visual with the patient. If phone only, page down to look at the phone codes. •CMS will pay for phone calls using codes 99441—99443, and 98966—98968. An AAPC webinar 3/31/2020 is stating that if the intent of the visit was patient initiated; not relating to an E/M within prior 7 days; not leading to an E/M service within next 24 hours or soonest available, use 99441-99443 and if the intent of the visit is for the E/M of an illness or injury, 99201-99215. If the circumstance of the visit is returning a call to a patient at their request, 99441-99443 but contacting a patient regarding their illness or injury either using audio and visual communication or using audio only because patient has audio only on phone or cannot access technology required to meet visual requirements of telehealth coding per CMS, use 99201-99215. Can you please clarify that per CMS guidance, which is your understanding, an audio telehealth E/M can be performed or the intent of the CMS guidance for adding audio is only if you use 99441-99443? Thank you, Debra

    • I don’t understand your question.
      For real time, interactive audio/visual, bill an E/M service. Audio only is not sufficient.
      For phone calls, use the phone call codes.

  7. From Noridian 3.31.20 it appears they want the “non-traditional” new temporary telehealth services to be billed with modifier 95 and regular POS and the “traditional” telehealth services to be billed with POS=02 and no modifier. Is that how you would interpret the text below?

    Billing for Professional Telehealth Services During the Public Health Emergency
    Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries, CMS will now allow for more than 80 additional services to be furnished via telehealth. When billing professional claims for non-traditional telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE), bill with the Place of Service (POS) equal to what it would have been in the absence of a PHE, along with a modifier 95, indicating that the service rendered was actually performed via telehealth. As a reminder, CMS is not requiring the “CR” modifier on telehealth services. However, consistent with current rules for traditional telehealth services, there are two scenarios where modifiers are required on Medicare telehealth professional claims:
    • Furnished as part of a federal telemedicine demonstration project in Alaska and Hawaii using asynchronous (store and forward) technology, use GQ modifier
    • Furnished for diagnosis and treatment of an acute stroke, use G0 modifier

    Traditional Medicare telehealth services professional claims should reflect the designated POS code 02-Telehealth, to indicate the billed service was furnished as a professional telehealth service from a distant site. There is no change to the facility/non-facility payment differential applied based on POS. Claims submitted with POS code 02 will continue to pay at the facility rate.
    There are no billing changes for institutional claims; critical access hospital method II claims should continue to bill with modifier GT.

    Thank you for your feedback

    • I would check back with them, since this contradicts what CMS released 3/30/2020. You can download what CMS released at the top of the article. Pages 13-15 describe place of service.

  8. Per the HR 748 CARES Act it seems that an RHC can be a distant site which would allow providers in RHC to provide telehealth services to their patients at home.
    Sec. 3704. Allowing Federally Qualified Health Centers and Rural Health Clinics to Furnish Telehealth in Medicare: This section would allow, during the COVID-19 emergency period, Federally Qualified Health Centers and Rural Health Clinics to serve as a distant site for telehealth consultations. A distant site is where the practitioner is located during the time of the telehealth service. This section would allow FQHCs and RHCs to furnish telehealth services to beneficiaries in their home. Medicare would reimburse for these telehealth services based on payment rates similar to the national average payment rates for comparable telehealth services under the Medicare Physician Fee Schedule. It would also exclude the costs associated with these services from both the FQHC prospective payment system and the RHC all-inclusive rate calculation.

    I would appreciate your interpretation of the above.
    Thank you.

    • The CMS document, listed at the top of the document, “CMS Source Documentation” has the section on rural health starting on page 82. You might want to look at that.

  10. MLN Connects, 3/31/2020, states Traditional Medicare telehealth services professional claims should reflect the designated POS code 02-Telehealth, to indicate the billed service was furnished as a professional telehealth service from a distant site. There is no change to the facility/non-facility payment differential applied based on POS. Claims submitted with POS code 02 will continue to pay at the facility rate. When billing professional claims for non-traditional telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE), bill with the Place of Service (POS) equal to what it would have been in the absence of a PHE, along with a modifier 95, indicating that the service rendered was actually performed via telehealth.

    Your article is stating “•On 3/30/202o2, CMS said you are not required to use POS 02, but should use the place of service that would have been used if the patient was seen face-to-face. This means, the office visit services will be paid at the higher, non-facility rate, not the lower, facility rate.”

    Also, your article is stating that for 99441-99443 (telephone E/M) that POS is not 02. Looking at the AMA CPT reporting for COVID-19 testing scenarios, they are stating that POS 02 would be used if 99441-99443 is being billed.

    Do you have any guidance on which non-traditional telehealth services would require the 95 modifier?

    • Hi, I realize that the MLN matters articles says POS 02. However, go to the top of the article and download the document “CMS source documentation” and look at pages 13-15.
      Despite what the AMA says, 99441–99443 are not telehealth services on the CMS list (you can download the list from the article, under the bullet that says “See the full list here.” Appendix P in the CPT book that lists telemedicine services does not have codes 99441–99443 on it. They are not telehealth services because they are done via the phone, and do not require synchronous, real-time, interactive audio and video.

  11. Hi Betsy, I am having trouble finding the updated list of codes from the CMS website, do you have a link you can share that has this updated information directly from CMS?

    • Go to the top of the article. Under “Medicare telehealth changes” look at the bullet that says, “See the full list here.” It’s there for you.

  12. Betsy, I am getting a lot of questions about “telemedicine in the facility”…i.e. both patient and MD in the same facility but need for “telemedicine” during this time is warranted, my guidance has been if it’s a visit with audio/visual communication then it’s telemedicine only during this PHE even if they are in the same location. I am taking that as inferred from CMS-1744-IFC would you agree? Thank you!

    • The last thing I saw about this was from March 17, 2020, from Medicare, “Medicare Telehealth FAQ” I haven’t seen this updated. If anyone else has, please add a comment.

      This is what they said then:
      15. Q: Should on-site visits conducted via video or through a window in the clinic suite be reported as telehealth services?
      A: Services should only be reported as telehealth services when the individual physician or professional providing the telehealth service is not at the same location as the beneficiary.

  13. Hello Betsy, please advise – CMS added physical therapy codes to telehealth, but did not add physical therapists as a non physician practitioner to be able to bill for it? Do I understand correctly?
    Thank you
    Kind Regards

    • That is what it looked like to me, and I don’t understand it. Perhaps a PT or OT on the site could communicate with their specialty society and provide guidance. I’m at a loss.

  14. Are the secondary/supplemental carriers required to pay the 20% with the new/expanded PHE circumstances from CMS for telehealth services? or, can they decline payment?
    This is questioned because:” The provider may waive the co-pay/deductible but is not required to do so.” thank you.

    • For CMS it is clear the physician may waive the deductible/co-pay but is not required to do so. For commercial carriers, I have not found a definitive answer. Will they pay 100%? Or, will they pay their portion and you will have the “option” to waive the patient due amount. I don’t know.

  15. We called CMS to request some clarification on the non-traditional telehealth codes, and CMS is advising that the traditional telehealth codes still be billed with POS 02 and that only the new list of non-traditional telehealth codes should be billed with the normal POS. The 03/31/2020 MLN Connects publication seems to support this. However, I wanted to ask if this is your understanding as well, or are you recommending that all telehealth (traditional and non-traditional) be billed with a normal POS? As always, your guidance is much appreciated.

    • CMS released the a Final Rule on 03/30/2020, effective date 3/1/2020. They changed their instruction to use the place of service that you would have used if you’d seen the patient in person. This allows you to get paid the non-facility, higher rate. The article is updated. You can read it for yourself, by downloading the document labeled “CMS source document” at the top of the article.

  16. Question regarding ER utilizing audio-visual E/M codes, place of service 23 with new/est E-M codes correct? Nothing different. They wouldn’t be able to utilizing the usual 9928X codes correct? Thanks Betsy! Again, appreciate all you have done and worked so hard during this time! You have helped me enormously! Wait, sorry, I just looked at your cheatsheet! So ER providers would be utilizing 9928X for medicare provided telehealth services? file:///C:/Users/fries/Downloads/cheat-sheet_covered-telehealth-services-for-phe_covid-19.pdf

  17. If provider is having video technical difficulties and converts to Telephone, in order to qualify or bill CPT 99441-43, shouldn’t the provider still be documenting time?

  18. Can I add to my previous question, I heard that as long as you have attempted the video call, you can still bill like it was a virtual visit if converted to telephone, or should it be CPT 99441-43?

    • I haven’t seen anything that an attempt was sufficient. I would bill 99441–99443 not office visit with real-time, interactive, audio visual.

  19. The CMS final interim rule regarding code selection based on MDM or time only applies to Medicare and Medicaid, correct? Any word on other payers following suit?

  20. What place of service to you utilize then for E-Visits? Not defined as telehealth

    Phone calls (99441–99443, 98966–96968) on-line digital E/M (99421–99423 and G2061–G2063), virtual check in (G2010, G2012) and remote monitoring are not considered telehealth services. Do not use POS 02 or modifier 95 with these.

    • Correct. These are not telehealth services. Look at the list in the CPT book and the CMS list (at the start of the article). Only services on those list are telehealth.

    • I would you POS home (and home visit codes), if the patient was homebound. If the patient normally would come into the office, I would use POS 11 and office visit codes.

  22. With regards to using 99201-99215 codes for telehealth, if a patient is seen utilizing the audio/visual on Monday, and the provider needs to see the patient in the office on Tuesday or Wednesday say for a BP check, is the telemedicine visit billable or is it considered related to the in person visit?

    • The two office visits via telehealth are billable. The issue of “not within 7 days of an E/M” or “resulting in an E/M in the next 24 hours or next available” relates to the telephone codes (99441-99443) and the on-line digital E/M codes (99421–99423). You can bill as many E/M services as are medically necessary, using the office visit codes.

  23. Betsy, am I correct that all of the services listed on your “cheat sheet” above, if performed via audio-video communication require the 95 modifier on each line item. As an example, outpatient 99211-99205 E/M codes, and inpatient 99221-99233 codes would all require the 95 modifier if performed via audio-video communication? If the services on your “cheat sheet” above are performed via audio only, then the 95 modifier would not be needed as they will be billed out 99441-99443 which are not telehealth codes?

    Your telemedicine Q&A states that AWV and Subsequent AWV real-time interactive audio/visual is required. Are there a list of services that CMS is requiring be used with real-time interactive audio/visual versus audio only?

    Again, thank you for all your guidance.

    Debra

    • Which cheat sheet? Do you mean the excel sheet that is listed as “List of covered telehealth services?” That is a Medicare document. Anything that is on that list, performed via audio/visual remote communications is considered to be telehealth.

      Audio only does not qualify as telehealth. 99441–99443 are not telehealth codes and do not require modifier -95.

      The excel list from Medicare is straight from their website.

  24. In regards to the question how we can bill when ED provider and patient are in different rooms in the ED and the ED provider evaluates the patient via video and audio, I learned from an ACEP (American College of Emergency Physicians) /CMS webinar today that this should be billed with regular ED codes. No modifier 95, as it does not constitute Telehealth. For Telehealth we would need two different locations. As it was explained, we can bill regular codes because the technology alone does not trigger a telehealth visit. I do not have a written source, but the webinar will be appear on the CMS resource library.

    • Thank you for sharing that. It would be great if ACEP would post a CMS citation. I do trust our specialty societies, because they often have direct access to CMS. If you get a link to the webinar, please share it with us.

  25. We have an internal medicine provider who was the admitting provider for a pt with Covid-19. At this time, the hospital is limiting the number of providers that can see this patient daily. Our provider is actively participating in the patient MDM by reviewing labs, tests, etc, managing medications, and is speaking with the family daily on the status of the patient and what is being done. Is there anything that the provider is able to bill for his time in the care for this patient in the ICU?

    • I also want to add that this pt is currently on a ventilator and only being allowed to be examined by the intensivist. Our providers were told that they would need to use the exam provided by the intensivist to do any further treatment.

      • Hospital and critical care services may be billed via telehealth, per CMS’s temporary addition to the telehealth list, published 3/30/20. However, telehealth does require two way, real time, audio/visual. I understand that the patient is intubated, and can’t participate, but we don’t have an exception in the rule. I’m sure that is why you wrote, because you are thinking about that component.

        Have you looked at the interprofessional consult codes? They are for internet based, medical record review and advice, without seeing the patient. They are time based. They aren’t the highest value codes, but don’t require physical seeing the patient. Take a look at the article on CodingIntel, Interprofessional Internet Consults. I think they describe the service that is being performed.

  26. Which POS should be used for telephone encounters 99441-99443 in outpatient physician office, 02 or 11??

    CMS – POS 11

    How about non Medicare ?

    Reading mix information, please advice

  27. At this point, if billing by provider time, use total time per CMS threshholds (different than CPT) and presently not use at all the face to face times codes we have all be use to for 23 years. Correct? Are private payers agreeing to this yet?

    • Correct. Use total time, including face-to-face via telehealth and non-face-to-face time by the billing clinician. Use the CMS chart. I haven’t seen anything from other payers.

  29. Betsy, with Medicare temporarily allowing CPT codes 99221-99223 for approved telehealth visits, can you please explain the difference in when you would use 99221-99223 and 99231-99233 versus G0425-G0427 and G0406-G0408? Thank you, Debra

  30. Hi Betsy,

    What is the allowed frequency of telephone calls (99441-43) per every 7 days? I say once every 7 days if no other E&M was performed during the 7 day period. I am getting a lot of push back from staff and providers who think telephone can be reported more than once per 7 days. I am holding steadfast with my statement.

    What are your thoughts?

    Thanks.😉

  31. Betsy,

    In this scenario:

    A patient comes into the provider office and the provider suspects he has COVID, does the office visit, flu test, CBC etc. sends the patient home but the provider doesn’t order a COVID test would this visit qualify for waiving member cost sharing and Modifier CS?

    Does modifier CS only come into play if an actual COVID test was done?

    Thanks so much for all your assistance!

  32. Let me know if this has been brought up before or not? I have reviewing CMS as well as numerous other resources and can’t find any information on this. Your thoughts would be greatly appreciated. The County Health Department is sending patients over to our clinic to be testing for COVID. They call us and tell us the patient is coming over to get tested. The provider goes outside, swabs the patient, gives them a little education, and then we send the lab. Can we be charging an office visit for the providers going outside and swabbing the patient? Providers are just questioning using a level 2 visit on these patients. We are looking for a way to get the supplies cost covered. I know there is a specimen handling cpt code we could use but majority of the insurance companies wont cover this because the lab isn’t being done here.

    • Hi, no I haven’t seen this covered. The AMA guide has an example of a nurse visit for this situation. (Which you can download from the main page).

      I don’t have a citation for this. Would it be reasonable/medically necessary to ask the patient a few questions, take their temperature and document the visit? Are they registered in your system? I wish I could answer definitively, but those are my thoughts.

  33. Thank you again Betsy for all your advice during Covid-19. Would you be able to expand on the ranking of modifiers between CS and 95? My thought would be that CS (cost sharing) would be in the 1st modifier spot secondary to being a pricing modifier and 95 for the synchronous audio-visual real-time telehealth?

  34. Hi Betsy, I interpret this paragraph from CMS FAQ 04/11/20, question 5, such that we can only append modifier CS if both is true, 1. the visit results in ordering or administering a Covid test AND 2. the services during the visit relate to Covid.

    I am not sure if this is correct. Can you advise?

    “Plans and issuers must cover items and services furnished to an individual during visits that result in an order for, or administration of, a COVID-19 diagnostic test, but only to the extent that the items or services relate to the furnishing or administration of the test or to the evaluation of such individual for purposes of determining the need of the individual for the product, as determined by the individual’s attending healthcare provider.16”

  35. Hi Betsy,

    One of our providers conducted a ZOOM visit and then sent the patient to the clinic to do a PFT test on the same day. Depending on the Payer would I have two separate encounters, one for the ZOOM with POS 2 and one for the PFT with POS 11? And then the 95 and 25 modifier on the ZOOM visit?

    I couldn’t find clarifying information for situation like this online and hope you can shed some light.

    Thanks again for all your updates!

    Tanya

  36. Betsy,

    Thanks for keeping this page updated. I teach other physicians about E/M coding and documentation and there is one question about telehealth E/M services that keeps coming up. Can we use MDM to select the level of care for all approved telehealth E/M services or only for new and established office patients? I have left dozens of messages to the people listed as CMS contacts for telehealth but have not heard back.

    • That section of the rule specifically says “office and/or other outpatient services.” It doesn’t list codes. I interpret this to mean CPT defined office and/or other outpatient services codes 99201–99215. When I look at CPT’s table of contents, this how they label those codes.

      • I realize that the rule only mentions the new and established office patients, but I believe the MDM rule came out before all the other E/M services were approved for telehealth.

        It seems to me it would be logical to extend the same process for selecting the level of care for all approved telehealth E/M services. It would not make any sense to have one set of rules for office patients and another for inpatients during the pandemic if the true goal is to expand the use of telehealth services to minimize risk to healthcare workers taking care of the sickest patients.

        For example, how could you possibly qualify for a 99285 level of care or a 99223 admission if you can’t select the level of care based on MDM. Do they expect a comprehensive exam to be done vie telehealth? I suppose it could be done, but it would just be gaming the process.

        I left my usual five messages with the person listed on page three of the source document who is supposed to be the contact for questions regarding telehealth.. Hopefully, some day she will respond. In the mean time, I guess I will have to educate physicians that the rules are uncertain and to document accordingly.

        • Thank you, these are good points, and I hope that you get a response. It does seem logical. If you find anything, please share it with us.

          I believe I am interpreting this correctly. The allowance to use MDM or time did come out in the March rule. There are HCPCS codes for ED consults and inpatient consults and subsequent visits that were on the CMS list, at that time. Since CMS was so specific about “office and other outpatient,” I am interpreting it to mean 99201–99215.

          I’d love to be wrong.

  37. Betsy,

    The April 30 updated Telehealth List contains code G9685 for Acute Nursing Facility Care. This has been a non-covered code, with the exception of use in a demonstration project for a handful of states. Can you link to any additional guidance or discussion regarding this newly-payable code? I read the entire IFR and didn’t see it addressed.

    Thanks so much for all your research and communication during this time –

    Jean

    • Hi Jean, I agree with you, it isn’t discussed at all in the rule, and is a temporary addition to the telehealth list, as fo 4/30/2020. Is there a reason to use it instead of 99307–99310 which are on the permanent telehealth list?

      • The allowable for G9685, managing an acute change of condition situation in a nursing home patient, is almost 50% higher than a 99310.

        After researching more today, I am inclined to think CMS added G9685 to the telehealth list but only for continued use within the demonstration project states. Still trying to confirm that.

  38. Reached MAC Novitas today, rep confirmed that G9685 was temporarily added to the Telehealth services during the public emergency but they are still following the existing guidelines to use only in the demonstration project and there are no new updates found for this code. So I guess that answers it!

  39. RHC/FQHC TELEHEALTH — Just thought I would add this as I have heard mixed communication on this since 04/30 with clients wanting to bill E/M 99201-99215 for telehealth in these two settings. The only code we can bill for telehealth visits right now is G2025.
    G0071 is used for digital e-visits and virtual check-ins.
    G2025 is used as a replacement for the codes on the CMS-maintained list…
    Nathan Baugh
    National Association of Rural Health Clinics

  40. Hello Betsy
    For a telehealth visit, you mentioned to bill “total time for the encounter” when billing time based E/M codes such as 99443 or 99213. Does this include time spent by the MA? Typically it takes several minutes for them to virtually “room” the patient, take a history, prepare chart, etc.
    Thank you!

  41. Hello Betsy: Thank you for educating us all. I have referred several people to you.

    I was recently told that for telephone audio only visits, that the ICD 10 codes in the notes will not be calculated in RAF score on those visits. Can you verify if this information is correct?

    Also, just to confirm…Telephone visits 99441-99443, now require a modifier 95?

    Thank you,
    Michael

    • This is the most recent document I’ve seen. It confirms telehealth visits for inpatient and outpatient claims will be counted, as I read the document. Telephone only codes are not mentioned, unfortunately.
      https://www.cms.gov/files/document/applicability-diagnoses-telehealth-services-risk-adjustment-4102020.pdf

      Yes, use modifier 95 on 99441-99443 because they are moved to the telehealth list.

      Thanks for the kind words, and referrals. It is a challenging time.

        • I don’t think you can submit a claim without a place of service code (but billing isn’t my specialty). I would follow the CMS guidance about other telehealth services, and bill the place of service that would have been used if the visit had taken place face-to-face. I expect most of these would be office or outpatient department.

  42. Thank you for such great articles! Are LCSWs and psychologists allowed to bill in-person therapy codes during the PHE via telehealth with Mod 95, or only the telephone codes listed above? Thanks! Jamie

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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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