You can add thousands of dollars in revenue for your telephone calls (99441-99443) thanks to new CMS rules. Pre-coronavirus, these codes netted a big fat $0. But now Medicare is paying up to $110 for a 30-minute call if you get your billing right.
To capture this added payment fast without facing improper claims penalties, you must nail down your CPT coding, modifiers, Place of Service (POS), and documentation. Follow these updated Medicare coding and billing rules to ensure you’re fully reimbursed for telephone and telehealth services.
Assign Telephone Code Based on 2 Factors
You should select the CPT telephone codes based on two details. By the amount of time your provider spends on the phone with a patient discussing their medical issues, and by whether the provider offering the services is a physician or other qualified healthcare providers (defined as those who are allowed to report E/M services). Here’s the breakdown of time and reimbursement for each:
Physician and nonphysician practitioner allowable codes:
- 99441: 5-10 minutes of medical discussion ($46)
- 99442: 11-20 minutes of medical discussion ($76)
- 99443: 21-20 minutes of medical discussion ($110)
Other qualified healthcare professional allowable codes:
- 98966: 5-10 minutes ($13-$14)
- 98967: 11-20 minutes ($26-$28)
- 98968: 21-20 minutes ($39-$42)
IMPORTANT: E/M services pre- and post-work values include a small amount of related care. Accordingly, you should not submit a claim a phone call when the time should be included in a related E/M service. Here are several circumstances in which telephone call time should be bundled with the office visit code, and you should NOT be separately billed:
- When the call is related to a face-to-face or telehealth visit that the patient has had within the past seven days
- The call results in the patient being scheduled for an upcoming in-person appointment within 24 hours from the call or the next available slot.
Check with Your MAC for Modifier Guidance
Several Medicare Administrative Contractors (MACs) recently changed their policy and now require that you append modifier 95 (Synchronous telemedicine service rendered via real-time interactive audio and video telecommunications system) when your physician provides separately billable telephone services. Initially, CMS did not require that you use modifier 95 for CPT codes 99441-99443 and 98966-98968, but as of April 30, 2020, that directive changed.
Tip: Some MACs are advising not to append modifier 95 to CPT codes 99441-99443 and 98966-98968. If there’s a discrepancy between the guidance of National Medicare and your MAC, follow your MAC’s rules. You’re obligated to abide by your MAC contract which may have a delay in changing rules after national Medicare guidance is announced.
Normal Care Location Drives POS
When billing Medicare with any of the telephone E/M services codes, your place of service (POS) code should be whatever you would normally use outside of COVID-19. This is true even if you’re not now providing the service from your usual location. For example, if your physician is now providing a telephone E/M service from her home due to COVID-19, but would normally provide it from your office, you’d use POS 11.
Get Paid More Without Refiling
If you submitted claims for telephone E/M services from March 2020 to the present (at the original, lower reimbursement rate), your MAC will automatically recalculate your claims and send you payment for the additional reimbursement you’re due. You do not need to refile. However, some MACs are reporting that CMS is giving them 30 days to make those changes in their system. So, even though you don’t have to take the time to refile these claims, you may have to wait a while before you receive the additional reimbursement.
Indicating Length of Time Is Key for Telephone Documentation
Clinical documentation requirements for telephone calls should support the level of service you’re billing, just like you would for an in-office visit.
Since 99441-99443 are time-based codes, be sure you are documenting time. While it’s helpful to document the service’s start and stop times, you must at least document the total time. Also, be sure to check with your MAC to find out if there are additional rules for documenting time.
Don’t Forget: Check with your commercial carriers—while some of them follow Medicare’s lead, others have different rules.
Emergency changes: There is so much more to know about telemedicine. The government regulations for of telemedicine is rapidly evolving. The only way to help your staff and your practice by using the applicable codes is to have a firm handle on the requirements.
That’s where nationally recognized coding expert and educator, Leonta Williams, MBA, RHIA, CCS, CCDS, CPC, CPCO, CEMC, CHONC, CRC, can help. In Earn $110 For Patient Phone Calls, New CMS Rule Applies, she’ll give you step-by-step advice on how you can increase your telemedicine and virtual care services reimbursement and avoid common compliance missteps.
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