COVID-19’s Effect on Telehealth Coding
COVID-19 Coding of Telehealth/Telemedicine/Remote Monitoring Services
With a staggering rise in telehealth visits, it is critical for Providers and coders to know how to document these services. A telehealth visit is defined as a visit with a clinician utilizing an interactive telecommunications system (audio and video) between a clinician and a patient and effective March 1, 2020, these services can be provided to new and established patients.
Medicare does not require that an informed consent be obtained from a patient prior to a telehealth-delivered service taking place. Medicare PHE flexibility allows these services to be provided to both new and established patients.
- 99201-99215 – Telehealth (audio and video) Services
COVID-19 Coding of Telephone Evaluation and Management Services
There are different codes for telephone (audio only) services defined as a visit with a clinician utilizing telephone (audio-only) between a clinician and a patient. It is critical for the Provider to document the time/minutes spent during the stated visit. Medicare PHE flexibility allows these services to be provided to both new and established patients.
These non-face-to-face services are defined as telephone evaluation and management services provided by a physician or other healthcare professional to a new or established patient, parent, or guardian not originating from a related E/M service provided within the previous seven days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment.
Before you start coding Telehealth visits, remember to think through the following distinctions:
- Is the visit initiated by a new or established patient?
- If the telephone service ends with a decision to see the patient within 24 hours or the next available urgent visit appointment, the code is not reported. The encounter is considered part of the preservice work of the subsequent assessment and management service, procedure, and visit.
- If the call refers to a service performed and reported within the previous seven days or within the post-operative period of the previous completed procedure, then the service is considered part of the previous service or procedure.
These are the applicable codes based on time spent in a telephone evaluation and management appointment:
- 99441 – 5-10 MINUTES OF MEDICAL DISCUSSION – A new or established patient known to the physician calls with a new complaint. The physician obtains a brief history and the patient’s present medication use and makes treatment recommendations, all of which are recorded in the patient’s medical record. The patient is instructed and advised to call if the symptoms fail to improve with the recommended treatment. The call lasts 8 minutes. No office visit is required.
- 99442 – 11-20 MINUTES OF MEDICAL DISCUSSION – A new or established patient calls the office of a physician to discuss new acute illness symptoms. The physician obtains a brief history and makes treatment recommendations, all of which are recorded in the patient’s medical record. The patient is instructed and advised to call if symptoms are increasing. The call lasts 15 minutes. No office visit is required.
- 99443 – 21-30 MINUTES OF MEDICAL DISCUSSION – Telephone evaluation and management service provided by a physician to an established patient, parent, or guardian not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 21-30 minutes of medical discussion
Medicare has increased their acceptance of Telehealth and has codes for Virtual Check-ins:
- G2012 – If a NEW and ESTABLISHED Medicare patient (waved E/M code can be used for both), A brief (5-10 minutes) check in with your clinician via telephone or other telecommunications device to decide whether an office visit or other service is needed.
- G2010 – – If a NEW and ESTABLISHED Medicare patient (waved E/M code can be used for both), A remote evaluation of recorded video and/or images submitted by an established patient.
Coders are familiar with modifiers: the numbers used to supplement information, adjust care description, or provide extra detail concern a procedure or service offered by a physician. Guidance for use of modifiers in relationship to Telehealth have also been released:
- Telehealth services provided via real-time interactive audio and video should be billed with the place of service (POS) code that would have been used had the service been provided in person, such as POS=11 (private practice) instead of 02 (telehealth).
- CMS has directed providers to append modifier -95 to all telehealth services billed using POS 11. This change will enable providers to be reimbursed at the same rate as services provided in person.
- Modifier -95 should not be used with virtual visits (G2012) or the digital evaluations (99421-99423). It is for use with all other telehealth codes that use synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system.
- GQ: Clinicians participating in the federal telemedicine demonstration programs in Alaska or Hawaii must submit the appropriate CPT or HCPCS code for the professional service along with the modifier GQ, “via asynchronous telecommunications system.”
Private payers and Medicare are not always aligned with their use of modifiers. You may find that private payers are still using the -GT modifier despite Medicare stopping use of this code in 2017 when the place of service code 02(telehealth) was introduced.
Lastly, during the current COVID-19 Public Health Emergency, telehealth E/M levels can be based on Medical Decision Making (MDM) OR time (total time associated with the E/M on the day of the encounter). Likewise, CMS has also removed any requirements regarding documentation of history and/or physical exam in the medical record for Telehealth visits.
If you have questions regarding ICD-10 codes or CPT lab testing codes related to COVID-19, refer to our previous blog: COVID-19’s Effect on Medical Coding.