As COVID-19 cases skyrocket in the U.S., telemedicine has emerged as an important tool to better care for people who have contracted the virus. Digital office visits allow symptomatic patients to stay at home and communicate with physicians on the status of their health, while protecting healthcare workers and the community at large. Providers need to know the rules for using telehealth to care for patients, including the relevant codes and how to bill telemedicine visits during this virus outbreak. Medicare and commercial payers have specific payment requirements for these virtual visits and rules are being constantly changed due to COVID-19. In these circumstances, the support of an experienced medical billing and coding outsourcing company could prove very useful for physicians to get reimbursed for COVID-19 related telemedicine services.
Billing Telemedicine Services during the COVID-19 Crisis
Telehealth, telemedicine, and telemonitoring generally involve the exchange of medical information between two sites through electronic communication to provide health care services. Effective March 6, 2020, the home can be the originating site during an emergency. For the duration of the COVID-19 Public Health Emergency, providers will be reimbursed for telehealth services furnished to beneficiaries in any healthcare facility and in their home.
The common telehealth approaches are as follows:
- Audio-Video visit -The telehealth codes for the E&M visits and typical times are as follows:
- Codes 99201–99215
99201 Office or other outpatient visit for the evaluation and management of a new patient, which requires these three key components: a problem focused history; a problem focused examination; and straightforward medical decision making – 10 min
99202… 20 min
99203… 30 min
99204… 45 min
99205… 60 min
99211… Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician or other qualified health care professional – 5 min
99212… 10 min
99213… 15 min
99214… 25 min
99215… 40 min
No modifier is required for Medicare claims with these codes. For commercial claims, use Modifier 95 or GT.
Other codes for telehealth are:
- G0425-G0427 Telehealth Consults, ER, Initial patient
G0425 Telehealth consultation, emergency department or initial inpatient, typically 30 minutes communicating with the patient via telehealth
G0426 …50 minutes…via telehealth
G0427 …70 minutes or more… via telehealth
- G0406-G0408 F-U, initial patient tele-consults – hospitals/SNFs
G0406 Follow-up inpatient consultation, limited, physicians typically spend 15 minutes communicating with the patient via telehealth
G0407 …25 minutes… via telehealth
G0408 …35 minutes… via telehealth
New guidelines for billing this type of telehealth visit starting March 17, 2020: In the current circumstances, the audio-video interaction between patient and provider can take place on Skype, Facetime, Zoom or Doxy. The A-V visit must be initiated by the patient (new or established). The office or other outpatient visit for the evaluation and management of a new patient requires these three key components: a problem focused history; a problem focused examination; and straightforward medical decision making.
Distant site practitioners who can furnish and get payment for covered telehealth services (subject to state law) can include physicians, nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologists, clinical social workers, registered dieticians, and nutrition professionals.
- Virtual Check-in: 5 -10 minute phone or video call – Can be any real-time audio (telephone), or “2-way audio interactions that are enhanced with video or other kinds of data transmission.” Unlike Medicare telehealth visits, virtual check-ins do not require audio and visual capabilities for real-time communication. There are specific rules for virtual check-in during the COVID-19 crisis. Codes to use for virtual check-in services are:
- Medicare HCPCS codes:
- G2010 – Remote evaluation of recorded video and/or images submitted by an established patient (e.g. store and forward), including interpretation with followup with the patient within 24 business hours, 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.
- G2012 – Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services.
Guidelines for billing Medicare virtual check-in codes:
- Call must be initiated by the patient
- Patient does not have to be established (during the COVID-19 crisis)
- Visit is not related to a previous E&M that has occurred in the past 7 days
- Cannot trigger a face-to-face visit within 24 hours (or first available)
- Patient’s verbal consent must be obtained prior to using and billing virtual check-in service
- No geographic restrictions for patient location – Place of Service (POS) is 11
- Communication can use non-HIPAA compliant technology during the COVID-19 public health emergency
- Nurse or other staff member cannot provide service represented by the above Medicare codes. It must be a clinician who can bill E&M services
- Telephone calls
Telephone only (no video) E/M services are reimbursable during this public health emergency by some payers. No modifier is needed for these codes because they are not telehealth – they are audio only telephone. (www.acponline.org). The CPT codes for billing telephone calls are:
99441 – 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, 5-10 minutes
99442 – Telephone evaluation and management service…11-20 minutes
99443 – Telephone evaluation and management service…21-30 minutes
98966 – Telephone assessment and management service provided by a qualified non-physician healthcare professional to an established patient, not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hrs or soonest available appointment, 5-10 min medical discussion
98967… 11-20 minutes
98968… 21-30 minutes
For these non-Medicare codes also, POS is 11.
E-Visits (Online Digital E&M)
E-visits are non-face-to-face patient-initiated communications with their providers using an online HIPAA compliant platform, such as an electronic health record portal, secure email or other digital applications. E-Visits may be billed using CPT codes 99421-99423 and HCPCS codes G2061-G2063, as applicable:
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… 11 – 20 minutes
99423… 21 or more minutes
Clinicians who may not independently bill for E&M visits (for e.g., physical therapists, occupational therapists, speech language pathologists, clinical psychologists) can also provide these e-visits and bill the following codes:
G2061 Qualified non-physician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the 7 days; 5–10 minutes
G2062… 11–20 minutes
G2063… 21 or more minutes
Considerations for billing E-Visits
- Can only be reported when the billing practice has an established relationship with the Medicare patients.
- Online patient portals can be used in all types of locations including the patient’s home, and in all areas (not just rural).
- Patients must generate the initial inquiry and communications can occur over a 7-day period.
- The patient must verbally consent to receive virtual check-in services.
- Medicare coinsurance and deductible would apply to these services.
- Practitioners who may independently bill Medicare for E&M visits (for instance, physicians and nurse practitioners) can bill E-Visits.
- Modifier 95 is used when synchronous telemedicine service is rendered via a real-time interactive.
- POS-2 should be to report the location when health services are provided or received through telecommunication technology.
- Modifier 95 should not be used with virtual visits (G2012) or the digital evaluations (99421-99423).
- Private payers may still be using the modifier GT. Medicare stopped the use of modifier GT when the place of service code 02 (telehealth) was introduced.
Besides using the correct HCPCS and CPT codes, it is also important to use the appropriate ICD-10 codes since some service cost sharing will be waived for COVID-19 testing and treatment. Outsourcing medical billing and coding to an experienced service provider can help with all of this. Medical coders in established medical billing companies stay up to date with the changes occurring due to the emergency COVID declarations, including the differences in Medicare and commercial payer rules. Expert coders can help providers stay compliant and receive appropriate reimbursement as they help patients utilize telehealth services to touch base with their providers on the status of their health.