A professional medical billing outsourcing company in U.S., Outsource Strategies International (OSI) has extensive experience in meeting the billing and coding requirements of almost all medical specialties.

In today’s podcast, Natalie Tornese, our Billing Manager discusses Telemedicine Coding and Billing during COVID-19.

In This Episode

00:25 Role of telemedicine during COVID-19

During this global COVID-19 pandemic, telehealth is emerging as an effective solution for precaution, prevention and treatment to prevent the spread of this infection.

01:10 Medicare rules for telemedicine

Just like other payers, Medicare has come up with certain key rules and regulations for billing and coding related to telehealth, telemedicine, and telemonitoring.

Hello everyone and welcome to our podcast series. My name is Natalie Tornese and I’m a Billing Manager at Outsource Strategies International (OSI). I wanted to take some time to talk about telemedicine, especially that it is such a hard topic right now with COVID-19.

As COVID-19 cases skyrocket, telemedicine has emerged as an important tool to curfew patients while maintaining social distancing. Telemedicine is a digital office visit that allows patients to communicate with physicians from only on the status of their health.

I am going to talk a bit on the rules and regulations for utilizing telehealth to care for your patients.

I will also include a transcript along with this podcast that will outline all the associated coding related to this.

Medicare and commercial payers do have specific billing, coding and payment requirements for these virtual visits and these regulations are constantly being changed due to COVID-19.

The guidelines that I will be discussing apply to telehealth, telemedicine, and telemonitoring, which generally involve the exchange of medical information between two parties through electronic communication. Effective on 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 as well as their home. The common telehealth approaches are as follows:

  • Audio-Video visits using E&M Codes 99201–99215
  • No modifier is required for Medicare claims with these codes.
  • For commercial claims, you would use Modifier 95 or GT, which I will discuss later.

Other codes for telehealth are:

  • G0425-G0427 Telehealth Consults, ER, Initial patient

The Telehealth consultation, emergency department or initial inpatient is typically 30 minutes for the G0425. And then for the other coding, you know it would depend on how many minutes the patient was being seen.

G0406 and the G0408 are Follow-up initial patient tele-consults for hospitals and skilled nursing facilities.

The Follow-up inpatient consultation, physicians typically spend 15 minutes for the G0406 and the minutes can go up for G0407 and G0408 respectively.

In the current circumstances, the audio-video interaction between the patient and provider is permitted to take place on Skype, Facetime, Zoom or Doxy. These new guidelines began on March 17th of 2020.

The A-V visit must be initiated by the patient, whether the patient be new or established.

The office or other outpatient visit for the established and the management of a new patient requires three components: a problem focused history; a problem focused exam; and a straightforward medical decision making.

Distant site practitioners who can furnish and obtain payment for covered telehealth services can include physicians, nurse practitioners, physician assistants, nurse midwives, CNAs, clinical psychologists, clinical social workers, registered dieticians, and nutrition professionals.

I’m going to discuss a bit about the Virtual Check-in codes which are G2010 and G2012.  The Virtual Check-in is a 5 –10 minute phone or video call. It can be any real-time audio (telephone), or "2-way audio interactions that are enhanced with video or other kinds of data transmission." These are unlike Medicare telehealth visits, as they do not require audio and visual capabilities for real-time communication.

  • G2010-Remote evaluation of recorded video and/or images submitted by an established patient, including interpretation with follow up 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 are

  • Call must be initiated by the patient
  • Patient does not have to be established (during the COVID-19 crisis)
  • Visit cannot be related to a previous E&M that has occurred within the past 7 days
  • The visit 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
  • There are no geographic restrictions for patient location – the Place of Service (POS) is 11
  • Communication can use non-HIPAA compliant technology during the COVID-19 public health emergency
  • Nurse or other staff members cannot provide the service, it must be a clinician who can bill E&M services

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 only audio, only telephone. The CPT codes for billing telephone calls are: 99441 - 99443 and 98966–98968

For these non-Medicare codes you are always going to use the POS as 11.

E-visits are non-face-to-face patient-initiated communications with their providers using an online HIPAA compliant platform, such as an EHR record portal, a secured email or other digital applications. E-Visits may be billed using CPT codes 99421-99423 and HCPCS codes G2061-G2063, as applicable.

Clinicians who may not independently bill using these E&M visits (for physical therapists, occupational therapists, speech language pathologists, clinical psychologists), they can also provide these e-visits by utilizing the following codes: G2061, G2062 and G2063. You can refer to the transcript that I’m going to include with this podcast.

The considerations for billing E-Visits are as follows -

  • They 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 and
  • Practitioners who may independently bill Medicare for E&M visits (for example, physicians and nurse practitioners) can bill E-Visits

Modifier 95 is used when synchronous telemedicine service is rendered via a real-time interactive. Synchronous telemedicine service is defined as a real-time interaction between a physician or other qualified healthcare professional and a patient who is located at a distant site from the physician or other qualified healthcare professional. 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. The GT modifier is used to indicate a service which was rendered via synchronous telecommunication. In 2018, CMS replaced the GT modifier with place of service code 02. However, this does not mean that the GT modifier is no longer recognized. Some private payers still recognize and prefer the GT modifier.

Besides using the correct HCPCS and CPT codes, it is also important to use the appropriate ICD-10 codes since some service cost sharing is not being waived because of COVID-19 testing and treatment.

I hope this helps, but always remember that documentation and a thorough knowledge of payer regulations and guidelines is critical to ensure accurate reimbursement for the procedures performed.

Thank you for your time!