Telehealth has been in the national media more often during the past few months due to the COVID-19 pandemic. However, even before the novel coronavirus outbreak hit the United States, approximately 76 percent of U.S. hospitals connected with patients and consulting practitioners at a distance through telehealth.

Although telehealth often is used interchangeably with the term “telemedicine,” it encompasses basic telecommunication tools, including phone calls, text messages, emails and which enable patients to communicate with their providers. Conversely, telemedicine consists of remote clinical services through technologies such as remote patient monitoring and live videoconferencing.

There are some medical billing guidelines specific to telehealth, and reimbursement policies vary from payer to payer and state to state. As of March 6, 2020, though, reimbursement for telehealth services provided to Medicare enrollees has been expanded on a temporary and emergency basis to enable patients to interact with their physician(s) without increasing their risk of being exposed to COVID-19.

This move was made by Centers for Medicare & Medicaid Services (CMS) through the Coronavirus Preparedness and Response Supplemental Appropriations Act and Section 1135 waiver authority. Before the expansion, the primary telehealth services for which clinicians were paid were routine visits under specific circumstances. In this blog, we’re providing an overview of medical billing standards used for telehealth services and how the CMS expansions differ.

Terminology and Tips

CMS requires that, in order to be reimbursed, telehealth services have to be provided through an interactive audio and video telecommunications system that enables real-time communication between the provider and the beneficiary. The only exceptions to this rule are Hawaii and Alaska, where asynchronous technology is permitted in federal telemedicine demonstration programs.

Before diving into some codes used regularly for billing telehealth solutions, it’s important to know some of the terms necessary for categorizing services. For example, the originating site is the location of the beneficiary at the time the service is furnished.

Prior to the COVID-19 pandemic, telehealth was considered a covered benefit only if the originating site was a county outside of a Metropolitan Statistical Area (MSA) or a rural Health Professional Shortage Area (HPSA) located in a rural census tract. CMS lists authorized originating sites as physicians or practitioner offices, hospitals, critical access hospitals (CAHs), rural health clinics, federally-qualified health centers (FQHCs), hospital-based or CAH-based renal dialysis centers, skilled nursing facilities and community mental health centers.

Another phrase in telehealth billing is distant site, which is where the provider delivering the service is located. Pre-COVID-19, distant site providers eligible to receive reimbursement for providing telehealth services were doctors, nurse practitioners, physician assistants, nurse-midwives, clinical nurse specialists, certified registered nurse anesthetists, clinical psychologists and social workers and registered dieticians or nutrition professionals.

Frequently utilized codes used in telehealth billing include:

  • New patient visits: 99201–99205
  • Established patient visits: 99212–99215
  • Consultations: 99241–99245
  • Codes for behavioral change interventions: 99406-99408

Similarly, codes used for Medicare Fee-for-Service Providers are:

  • Follow-up inpatient telehealth consultations provided to beneficiaries in SNFs or hospitals: HCPCS codes G0406–G0408
  • Individual and group behavior and health assessment and intervention: CPT codes 96150–96154
  • Telehealth consultations initial inpatient or emergency department: HCPCS codes G0425–G0427
  • Individual telemedicine psychotherapy: CPT codes 90836–90838 and 90832–90834
  • Telehealth pharmacologic management: HCPCS G0459

Another notable telehealth billing term is Place of Service (POS) codes. POS codes are used by a provider to inform payers through a billing form where the provider and patient were located during a health encounter. If synchronous telehealth services were used with a Medicare patient, POS 02 has to be included on the bill. Following are a few other instructions from CMS on telehealth billing:

  • If you performed telehealth services “through an asynchronous telecommunications system”, add the telehealth GQ modifier with the professional service CPT or HCPCS code (for example, 99201 GQ).
  • Bill covered telehealth services to your Medicare Administrative Contractor (MAC).
  • HCPCS Code Q3014 describes the Medicare telehealth originating sites facility fee. Bill your MAC for the separately billable Part B originating site facility fee.

COVID-19 Coding Changes

The key goals of the CMS measures to expand telehealth services during the COVID-19 pandemic are to conduct telehealth with patients located in their homes and outside of designated rural areas; practice remote care, even across state lines; deliver care to both established and new patients; and bill for telehealth services (both video and audio-only) as if they were provided in person. CMS has on its website a complete list of services payable under the Medicare Physician Fee Schedule when furnished via telehealth and additional services and corresponding codes clinicians are now able to provide during the novel coronavirus public health emergency.

According to CMS, providers independently billing Medicare for evaluation and management visit should use the following codes:

  • 99421: Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5–10 minutes
  • 99422: Online digital evaluation and management service, for an established patient, for up to 7 days cumulative time during the 7 days; 11– 20 minutes
  • 99423: Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 21 or more minutes.

Most commercial payers require Modifier 95 to be used on an interim basis for Medicare telehealth billing. Providers who bill Medicare telehealth services during the COVID-19 outbreak should utilize the same POS code they typically use when billing for in-person services. The GQ Modifier should only be used when telehealth services are delivered to patients through an asynchronous telecommunications system.

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