April 01, 2020

CMS Defines Terms for Telehealth Use During COVID-19 Crisis

The Centers for Medicare and Medicaid Services (CMS) defines telehealth services as office visits, psychotherapy, consultations, and certain other medical or health services that are provided by an eligible provider who isn't at your location using an interactive two-way telecommunications system (like real-time audio and video). The original intent was to provide services to rural areas with significant restrictions (e.g., the provider was required to provide such services from specific locations as designated by CMS).

As of March 6, 2020, CMS has instituted a temporary emergency broadening of access to Medicare telehealth services in response to the coronavirus disease (COVID-19) crisis.

Under both legislative and Section 1135 waiver authority granted to CMS, Medicare providers now may use telehealth technology when providing various services to patients including evaluation and management (E/M) services that previously required face-to-face visits.

Some important additional changes include:

  • All telehealth services will be reimbursed at the same rate as an in-person visit for both COVID-19-related diagnoses as well as any other diagnosis.
  • Patients will not be required to have an established relationship with the physician to receive telehealth services.
  • Services can be provided to patients in a state other than the one in which the physician is licensed (applicable to both Medicare and Medicaid patients).
  • During this emergency, telehealth services may be provided in all settings, regardless of the patient’s or provider’s location. In particular, patients outside of rural areas and patients in their homes will be eligible for telehealth services.
  • The Department of Health and Human Services Office of the Inspector General is providing flexibility for health care providers to reduce or waive cost-sharing for telehealth visits paid by federal health care programs.
  • Physicians as well as qualified providers, including nurse practitioners, physician assistants, clinical psychologists and licensed clinical social workers, can bill for these services.
  • Health Insurance Portability and Accountability Act (HIPAA) requirements have been relaxed during the COVID-19 emergency to allow the use of certain non-HIPAA-compliant video communication platforms, such as FaceTime.

Important Coding and Reimbursement Tips:

  • Coding
    • Telehealth visits (CPT 99201-99215, HCPCS G0425-G0427, and HCPCS G0406-G0408)
    • Virtual Check-ins (HCPCS G2010 and G2012)
    • E-visits (CPT 99421- 99423 as well as HCPCS G2061-G2063)
    • Telephone (CPT 99441-99443).
    • Radiation Treatment Management (CPT 77427)

Medical record documentation should include:

  • Patient history, review of systems, acknowledgement of review of available consultative notes and information utilized for medical decision making.
  • Physical exam to the extent possible. This can be accomplished with patient assistance, such as reporting of temperature, blood pressure, description of any areas of pain, and, if needed, video-based review of organ systems.
  • Communication platform utilized for visit depending on if Telehealth or E-visit. This can be telephonic and/or a specific video platform.
  • Documentation of other persons who attended the encounter.
  • Documentation that the visit occurred during the COVID-19 crisis period as well as the date and time of the encounter.
  • Documentation must indicate if this is a Telehealth (virtual), E-Visit or Virtual Check-in encounter.

Telehealth services can be provided via telephonic communication and/or via a video encounter. They should be billed with Place of Service (POS) equal to what it would have been had the service been furnished in-person. Modifier 95, Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications System, should also be applied indicating that the service was provided via telehealth. These codes will be reimbursed at the facility rate.

Many commercial payers have also temporarily modified their payment rules relating to telehealth visits. It is recommended that you contact your local payers directly in order to discuss their most current payment rules.

For more details, please refer to CMS Flexibility Rules Related to COVID-19, CMS Factsheet, FAQs, AMA COVID-19 Coding Advice and Telehealth Codes.