After a year of constant updates, the rule changes for telehealth coding have “finally” been finalized in the 2021 Physician Fee Schedule final rule. Keep reading to ensure you’re getting paid for every service—including the newly reimbursable telehealth codes.
CMS Adds Services to Telehealth List. Beginning January 1, 2021, the list of services reimbursable when provided via telehealth has grown. Many of these 60+ new telehealth codes were added under Category 1—services similar to those already on the telehealth list—so there are unlikely to be any big surprises. Examples include:
- Prolonged services (G2212)
- Home visits (99347, 99348)
- Care planning for cognitively impaired patients (99483)
- Group psychotherapy (90853)
- Psychological and neuropsychological testing (96121)
- …and more
CMS did not add any Category 2 services for 2021.
Note: Category 2 telehealth services are those that are not similar to those already on the list.
Look Out for 12 Temporary New Telehealth Codes for 2021
CMS did add a new category—Category 3. This category is for temporary codes for services added under the COVID public health emergency (PHE). Telehealth reimbursement for these codes will eventually expire, either when the PHE ends, or through December 31st of the year in which the PHE ends.
Category 3 codes have been added throughout the PHE, but CMS added 12 new services (encompassing multiple codes) in the 2021 MPFS Final Rule. They include:
- Emergency department visits
- Custodial care services
- Therapy services
- Hospital discharge day management (including observation and nursing facilities)
- Critical care services (including neonatal and pediatric)
- ESRD monthly capitation codes
- …and more
You can obtain a full list of Category 1 and Category 3 codes by downloading the “List of Medicare Telehealth Services” spreadsheet here.
Note: For some of these services, audio-only telehealth visits meet the requirements for payment, while other services require audio and video interaction. This is also noted on the CMS spreadsheet.
Telehealth Place of Service Codes Stay Simple (Mostly)
For Medicare and many major private payers, use the place of service code that you would have used had the service been provided in person. This includes both new and established patients, audio/visual or audio only visits, and both COVID and non-COVID related care. The private payers adhering to this rule include:
- Aetna (but only for Medicare Advantage plans)
Exceptions: For Aetna’s commercial plans and UnitedHealthcare plans, use place of service code 02. Anthem’s rules vary by state, so check your LCDs.
Caveat: Use the wrong place of service, and your payment could be cut. For example, Medicare will pay telehealth visits that would normally be office visits (coded with POS 11-office) at the same rate as the regular office visit. But mistakenly use POS 02-telehealth, and your payment could be denied or paid at a reduced rate. In contrast, UHC telehealth claims coded with any POS except 02 will be denied.
Good news: Many payers will automatically reprocess your already-submitted claims that were previously denied due to POS type error. But beware: for some payers, you must take action and resubmit those claims. This depends on your state and plan, so check with your payers. For example:
- BCBS plans in Florida and Illinois will automatically reprocess claims denied due to POS errors (effective March 19, 2020)
- BCBS Regence plans in Oregon and Washington must be resubmitted by the provider
Note: The Final Rule specified that telehealth payment requirements do not apply if, when the telehealth visit takes place, the patient and the provider are in the same physical location but simply conducting a virtual visit to limit COVID-19 exposure. For example, if the provider is in an office and the patient is in an exam room in the same building.
As you can clearly see, these new telehealth rules are tricky, but the reimbursement you will receive by correctly billing them is worth the effort. National coding expert and educator, Kim Huey MJ, CHC, CPC, CCS-P, PCS, CPCO, will show you how.
During her online training she explains exactly how you can ethically maximize reimbursement for your telehealth services using these new rules – and how to STOP providing your virtual services for free.