CMS expands Coverage for Phone Assessment and Management Services

by | Published on May 18, 2020 | Healthcare News

Coverage for Phone Assessment and Management Services
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There’s good news for psychologists and other qualified healthcare professionals who provide phone consultations. During the COVID-19 public health emergency, the Centers for Medicaid and Medicare Services (CMS) will reimburse many audio phone-only behavioral health and patient education services. Medical billing companies can use specific codes to help psychologists submit claims for services delivered via telephone. Phone only services are retroactive to March 1, 2020.

Leading industry associations noted that many seniors and low-income families lack access to mobile health devices with video capabilities or broadband capabilities ( In an announcement issued on April 30, CMS eased the restrictions around phone-based services during the period of the COVID-19 emergency.

“Psychologists can now use their speciality skills to improve the health of ALL the communities we serve, including older adults, people with lower income or education, individuals with disabilities and people in rural areas,” said Arthur C. Evans Jr., PhD, CEO of the American Psychological Association.

The American Medical Association (AMA) also applauded CMS for allowing Medicare beneficiaries in under served areas to access care from their homes.

“With physicians reporting that Medicare patients are cancelling needed medical appointments because of physical distancing and transportation challenges. This is a major victory for medicine that will enable physicians to care for their patients, especially their elderly patients with chronic conditions who may not have access to audio-visual technology or high-speed Internet. This change will help patients address their health challenges that existed before COVID-19,” said the AMA.

CPT Codes for via Phone Only and Traditional Telehealth Services

Audio-only behavioral health services can be billed by: all providers eligible to furnish audio-only E&M services (except that only behavioral health FQHCs are eligible and family planning clinics and CNMs are not eligible), plus rehabilitation clinics, independent licensed behavioral health clinicians (licensed psychologists, licensed clinical social workers (LCSWs), licensed marital and family therapists (LMFTs), licensed professional counselors (LPCs), and licensed alcohol and drug counselors (LADCs).

Don Self and Assoc. Inc. listed the key improvements that CMS made to telehealth on April 30, 2020, as follows:

  • 91 CPT/HCPC codes that can be billed telehealth performed by phone only
  • 244 codes on the telehealth listing
  • Almost tripled payment amounts for phone visit codes 99441-99443
  • Allows use of CPT times for telehealth documentation
  • Confirmed modifier 95 for Medicare Part B telehealth services
  • Allows use of 99211 for COVID specimen collection instead of G2023
  • Confirmed same POS of provider-patient to be non-telehealth
  • Increased payment for RHC/FQHC for phone calls
  • Allows RHC/FQHC to bill all 244 Telehealth codes

Traditional telehealth or phone only services should be billed in the same way as office visits using the following CPT codes (

  • Diagnostic Interview (90791, 90792)
  • Psychotherapy (90832, 90833, 90834, 90836, 90837, 90838)
  • Psychoanalysis (90845)
  • Group Psychotherapy (90853)
  • Family Psychotherapy (90846, 90847)
  • Crisis Intervention and Interactive Complexity (90839, 90840, 90785)
  • Neurobehavioral Status Exam (96116, 96121)
  • Psychological Evaluation (96130, 96131)
  • Neuropsychological Evaluation (96132, 96133)
  • Psychological and Neuropsychological Test Administration and Scoring (96136, 96137, 96138, 96139)
  • Health Behavior Assessment (96156)
  • Health Behavior Intervention, Individual (96158, 96159)
  • Health Behavior Intervention, Group (96164, 96165)
  • Health Behavior Intervention, Family with patient (96167, 96178)
  • Behavioral Screening (96127)
  • Screening, Brief Intervention, and Referral to Treatment (G0396, G0397)

Billing Considerations

  • For both E&M and behavioral health services rendered by telephone, providers:
    • Can only bill for services to established patients and for services that would be covered in person, but for the current COVID-19 pandemic
      When providing audio-only telehealth services, providers should obtain verbal consent for these services and document the consent in the medical record
  • There should be procedures to verify provider and patient identities, adhere to all coding requirements and federal and state billing regulations
  • All services rendered should be completely documented, including that the service was furnished by telephone

Place of Service (POS)

There is no restriction on the location of the provider when furnishing telehealth services. When providing services via phone, the place of service (POS) used should be that which would have been reported if the service had been furnished in-person. For example, as a psychologist would have seen patients in a private office, POS 11 should be used. If the qualified professional treated the patient in an independent clinic, POS 49 should be used. If the patient was seen in a skilled nursing facility, the POS would be 31.

Providers should ensure that they are adhering to EHR guidelines for documenting services accurately at this time, notes Maria Noelle Ward, MEd, director of HIM practice excellence at AHIMA (www. Precise documentation will provide higher quality data that can impact patient outcomes in the future.

Rules and regulations around the COVID-19 crisis seem to be changing as new information emerges. In this situation, the best option for healthcare providers is to partner with a medical billing and coding company that can help them diligently follow coding and billing guidelines from the CDC, CMS, AMA, and other official industry organizations.

However, as DonSelf points out, Medicare’s rules are different from CPT in several areas. Understanding these differences would go a long way in getting paid. For instance, per the AMA CPT book, modifier 95 means: “synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system. However, according to Medicare’s latest guidance (issued a just over a week ago), 91 services with phone calls only can be reported with the 95 modifier. Only billers and coders who stay up to date on the latest payer guidance can help physicians ensure accurate claim submission and maximize reimbursement.

Julie Clements

Julie Clements, OSI’s Vice President of Operations, brings a diverse background in healthcare staffing and a robust six-year tenure as the Director of Sales and Marketing at a prestigious 4-star resort.

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