Important: Your CPT codes 99201-99215 claims are under attack. CMS and private payers started their telehealth exam post-payment audits which include reviewing your records and contacting your patients.
Address these telehealth audit targets right now so you can hold onto more of your office visit pay and prevent future compliance penalties.
Telehealth Exams Must Include Video
If you billed CPT codes 99201-99215 for telehealth visits, one of the things auditors will be investigating is if your encounters used same-time audio and video. Auditors will be contacting your patients to verify the service’s components. Be prepared to deal with both claims for which you have already been paid, are pending reimbursement, and ones you file in the future. CPT telehealth audits.
- Paid Claims: You will need to repay the reimbursements. The sooner you identify problems, the more forgiving auditors will be. Begin notifying patients that they will receive inquiries about their remote visits. Do not suggest to patients to lie or how to respond to these inquiries.
- Pending Payment: Immediately, take the steps required to refile any of your outstanding claims with the proper coding.
- Future Services: For upcoming audio-only visits, report the services using the appropriate CPT telephone call code 99441-99443 (Telephone call from a practitioner or non-physician practitioner authorized to provide evaluation and management services) approved by the payer.
- More Tips: There’s more help from nationally recognized coding expert and educator, Leonta Williams, MBA, RHIA, CCS, CCDS, CPC, CPCO, CEMC, CHONC, CRC. During her upcoming online training session “Stop Telehealth Payer Audits from Taking Back Your Reimbursements,” you’ll receive step-by-step expert advice on how you can hold on to more of the telehealth payments you’ve received, and how to avoid future errors that could get you in trouble.
Record Non-Compliant Platform Warning
You should review your existing records, identify gaps, and educate staff on how to improve future telehealth service documentation. Auditors will be looking for the:
- Telehealth platform used for your telehealth visits and if it’s HIPAA compliant.
- Informed verbal consent that your patient understands and is okay with the limitations of a teleheath exam and that normal billing applies.
- Time spent with patient including the start and end time of the telehealth visit. Many telehealth codes are based on time spent with patient.
Auditors are aware that during the public health emergency (PHE), the Department of Health and Human Services (HHS) allowed you to use non-public facing audio or video platforms such as Skype and Apple FaceTime for telehealth visits. But they will be searching to make sure you alerted patients before the televisit and warned them of the security risks. CPT telehealth audits.
Medicare defines telehealth exams as virtual encounters by practitioners that include same-time audio and video. When a visit does not contain the video component, you should instead report a telephone call service for Medicare. During the Public Health Emergency (PHE), CMS began paying telephone calls at the same rate as the equivalent office visit code. CPT telehealth audits.
Here are the common codes you should have reported for telehealth visits and should on claims going forward:
- 99201-99215 – Evaluation and management (E/M) codes for office or other outpatient s Many private payers reimburse telehealth visits under established patient codes 99211-99215
- 99441-99443 – CPT codes for telephone calls, limited to physicians and nonphysician practitioners. Prior to the public health emergency, CMS did not provide separate payment for the services. Retroactive to March 1, 2020 CMS began reimbursing phone calls at the same rate as the equivalent level office visit.
Telehealth Modifiers :
- 95: Synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system
- CR: Catastrophe/disaster related
CMS Reimbursement: To get reimbursed from CMS for telephone calls you must bill using the telephone codes 99441-99443, not the standard telehealth office visit codes 99201-99215. Also, use modifier 95 for all Medicare professional telehealth claims during the public health emergency and modifier CR for Medicaid telehealth claims. CPT telehealth audits.
Best bet: Double-check with private payers for billing guidance. While some will follow CMS guidance others may set different rules. Some COVID-19 resources for commercial payers include:
- United Healthcare
- Center for Connected Health Policy (CCHP)
- American Health Insurance Providers (AHIP)
Telehealth Training Resources Selected For You
|Comply with Tightened Post-COVID-19 HIPAA Telehealth Rules
||New HHS Rule: Avoid Losing Your COVID-19 Emergency Relief Money
||Stop Telehealth Payer Audits from Taking Back Your Reimbursements