CMS, at the order of the U.S. legislature, has altered some practices to address the coronavirus crisis better. Loosening restrictions on telehealth or telemedicine reimbursement is one of the most significant changes that the government has enacted. In the past, CMS reimbursed for these services on a limited basis only. As of recent regulatory changes, providers can now bill for telehealth visits at the same rate as in-person visits during this emergency declaration period. Now, providers have much more freedom to see patients via phone or virtual visits using interactive apps, such as Otto Health Telehealth or Zoom, instead of in person. This step allows patients to get at least some of the health care they need without leaving home and increasing their chances of contracting the virus. It also helps your physicians, nurses, and staff stay safe during the pandemic. This temporary regulatory change is particularly helpful for keeping patients with COVID-19 symptoms at home where they are not spreading the virus. It also helps the elderly with multiple comorbidities for whom the virus is particularly dangerous.Of course, these changes pose some challenges for already overburdened staff members, who need to alter their coding for billing practices. Fortunately, the CMS billing guidelines are relatively simple and are based, for the most part, on waiver 1135. These coding practices are already in effect and will remain so until further notice. While CMS is making things simpler, many payers are still catching up to these changes with varying success. As such, confirm with your major payors guidelines prior to submitting telehealth visits.
Prior RelationshipThe previous regulations stipulated that CMS would not pay for telemedicine visits unless a previous relationship existed between the patient and the physician. For the duration of the current crisis, that rule has been waived. Or, more precisely, the HHS will not conduct audits during this medical emergency to determine if a prior relationship existed. This policy change means that providers have an opportunity to offer telehealth care to many more patients, especially vulnerable populations. Your billing personnel may not have much experience in submitting telehealth claims, however. In response, the CMS has offered clear guidelines on which codes should be used to receive timely reimbursement. They are as follows:
Bill Medicare Telehealth VisitsA telehealth visit is defined as "a visit with a provider that uses telecommunication systems between a provider and a patient." Common codes for these visits include:
- 99201-99215: Office or other outpatient visits
- G0425-G0427: Telehealth consultations, emergency department or initial inpatient
- G0406-G0408: Follow-up inpatient telehealth consultations furnished to beneficiaries in hospitals or SNFs
Virtual Check-inThese telehealth visits are still covered for established patients only and consist of a short check-in by telephone or computing device. They are most often used to decide if a patient needs an office visit or some other medical service. Your staff may use the following codes for billing:
- HCPCS code G2012
- HCPCS code G2010
E-VisitsE-visits are defined as "a communication between a patient and their provider through an online patient portal." The appropriate codes for these visits include the following:
Telehealth ModifiersThere are no new modifiers required by the CMS. There are still three cases where existing modifiers should be used:
- GQ modifier - When "a telehealth service is furnished via asynchronous (store and forward) technology as part of a federal telemedicine demonstration project in Alaska and Hawaii..."
- GT modifier - When you bill the telehealth service under CAH Method II
- G0 modifier - Necessary when the telehealth service is used to diagnose and treat an "acute stroke."