QUESTION: We are really confused on the constant telehealth regulatory changes. Our providers understand that new codes qualify with less supervision – and even without audio. We have several elderly patients who require ongoing care. Can you provide us with some recent options for CMS paid telehealth so we can continue to care for our patients and receive payment compliantly?
Naples, FL Subscriber
ANSWER: Medicare has made numerous rule changes over the last few weeks which has confused numerous practices across the country. So, you are certainly not alone. Although keeping up with Medicare rule changes can seem impossible, it is imperative to help you ensure accurate payment for your telehealth services.
To optimize your virtual care options and accurately code and bill for these services based on the April 1st Published Interim Rule, you should follow five key takeaways:
- 80 new codes now qualify under telehealth: CMS added numerous services to the list of approved telehealth codes including hospital care (99221-99239), nursing facility care (99304-99316), and rest home care (99327-99377). These new services must be provided by a physician or nonphysician extender.
- E/M code preferred when appropriate: You should use the code that best describes the service provided. When an E/M code better describes a telehealth service, report the applicable CPT code rather than a digital code. For instance, a hospitalist requests a consult for an inpatient with renal disease from a nephrologist who performs subsequent hospital care via audio-visual technology. Accurate coding for the service is appropriate E/M code of subsequent hospital care (e.g., 99232). Prior to the April 1 rule, Medicare instead required G0425-G0427 (Telehealth consultation). Remember, per the regulation to apply modifier 95 to indicate the service was performed by telehealth and use the “normal” place of service code (21, Inpatient Hospital).
- Telehealth ‘requires’ video component: The rules all stress this. However, you should really take the time to get through to your MAC. Many contractors understand that elderly patients as well as patients with hand impairing conditions cannot adopt video technology. Therefore, the payers are allowing billing telehealth codes without video. First Coast Service Options of Florida, Alabama Medicaid, and other contractors have verbally confirmed to use E/M codes with modifier 95 for virtual care without video.
- Phone call codes are payable: Codes 99441-99443 for physician phone calls are also payable retroactive to dates of service of March 1 along with all of the rule’s changes. The telephone call CPT codes had been assigned a status of always bundled and therefore not separately payable. However, CMS now considers these payable as long as you do not bill an E/M or telehealth service during the same 7-day period. Because these codes pay less ($14-41) than the E/M code ($23-$211), try to negotiate with your contractor to get the E/M codes covered for providing services without video.
- Incident-to rules allow telehealth supervision: Your physician can now provide direct supervision via audio-video. CMS is temporarily changing the definitions for incident-to billing to allow physicians to monitor services from home to reduce exposure during the emergency.
There are still more changes including using medical decision making or time to select the E/M code, added allowances for nonphysicians to provide virtual services, and other expansions. Learn the latest reimbursement rules in Leonta Williams, MBA, RHIA, CCS, CCDS, CPC, CPCO, CEMC, CHONC, CRC, online training session “CMS Revised Telehealth COVID-19 Rule: Get Paid More”.
