Updated: May 15, 2020
Read the article about modifier CS and cost sharing here
- Telehealth Q&A
- CMS Interim Rule – March 30, 2020
- CMS Interim Rule – April 30, 2020
- Selecting a level of service for a significant change to E/M rules and telehealth
- “Coding and Reimbursement during the COVID19 Pandemic” created by Elizabeth Woodcock, of Woodcock & Associates.
- List of covered CMS telehealth services
- AHA Coding Clinic advice, diagnosis for COVID-19
- CMS Updated FAQ 4/29/2020
- Behavioral health and telemedicine
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)
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.
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|
- Coding Guidance from the AMA
- CMS enrollment COVID-19PEHotline
- Aledade guide to getting started with telehealth
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.
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.
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.
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.