Virtual communications are not considered telehealth
- These HCPCS codes were developed by CMS for virtual communication
- Do not use POS 02 or modifier 95 on these services for Medicare claims with these codes, because they are not considered telehealth
- They are not on CMS’s list of telehealth services and do not use real-time, interactive, audio/visual communication
- They do require verbal consent; a single consent can be obtained for all communications based technology services annually
- There is a link to a video that includes discussion of these codes at the end of the article
CMS said it doesn’t consider these to be telehealth services, although they are using “technology-based” and so they don’t need to meet the requirements of telehealth.
G2012 brief communication technology-based virtual check-in
What technology can be used for this technology-based check-in?
Well, it includes the telephone. Here’s a quote from the 2019 Final Rule:
“We are persuaded by the comments advising us not to be overly prescriptive about the technology that is used, and are finalizing allowing audio-only real-time telephone interactions in addition to synchronous, two-way audio interactions that are enhanced with video or other kinds of data transmission. We note that telephone calls that involve only clinical staff could not be billed using HCPCS code G2012 since the code explicitly describes (and requires) direct interaction between the patient and the billing practitioner.”
The service could be performed using more advanced technology, such as a patient portal or a HIPAA compliant video service. But, burying the lede here, they are allowing telephone.
This code is for use when the check-in does not result from a service within the past 7 days, or result in a service in the next 24 hours, or next available appointment. It is for a brief, non-face-to-face service provided by a physician or non-physician practitioner, not a staff member. It may be used only for established patients. The provider must have E/M in their scope of practice, so social workers and other types of therapists may not use it. It is used to determine if an appointment is needed.
It does require verbal consent to bill and is subject to co-insurance and deductible.
G2012 Brief communication technology-based service, e.g., virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, 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
G2252 11-20 minutes of medical discussion
G2010, store and forward
Did you ever want to send a picture to your doctor of your rash? Or that tick that was crawling up your arm? Well, now is your chance. Your doctor/NP/PA will be paid $12 or $13 to look at your picture or video!
This code has the same requirements that it does not arise from a service within the past 7 days or result in a service in the next 24 hours or next available appointment.
The practitioner looks at the image or video, and there is subsequent communication by the practitioner or staff member to the patient. Follow up is required. The follow up could be a portal message or a phone call. If the image is insufficient to make a determination, it can’t be billed.
It also requires consent (verbal, written or electronic) and the charge will be subject to co-insurance and deductible. It may only be provided to an established patient.
G2010 Remote evaluation of recorded video and/or images submitted by an established patient (e.g, store and forward), including interpretation with follow-up with the patient within 24 business hours, 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
Clinicians without E/M in their scope of practice
CMS also developed HCPCS codes for clinicians who can’t bill office visits or other E/M services but who are able to enroll in Medicare and report their services. This includes social workers, physical and occupational therapists, and speech language pathologists.
G2250 Remote assessment of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment
G2251 Brief communication technology-based service, e.g. virtual check-in, by a qualified health care professional who cannot report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion
CPT® codes (99421-99423) – and payment for – online digital evaluation and management (E/M) services
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