Updated 3/25/2020
CMS has released more relaxed guidelines for Telehealth refer to CMS Medicare Telemedicine Health Care Provider Fact Sheet
During the Coronavirus (COVID 19), crisis managing patients while abiding by social distancing protocols is essential. Telehealth options can help in the following ways:
- Healthy patients who have regular or follow up appointments can avoid exposure by opting to have a telehealth appointment instead.
- Primary care providers, usually a patients first point of contact, can use telehealth options as a method to triage patients while keeping their patients and staff safe.
- Hospitals can ask non-urgent patients to use telehealth as an option allowing providers to focus on the ER cases and those patients needing care from COVID 19.
In no way is this to discourage patients from getting the care needed, rather to be open to Telehealth options. This provides safer options for staff and the ability to manage patient volume.
Billing for Telehealth Services
Eligible providers who can provide telehealth-delivered services:
- Physicians, nurse practitioners, nurse midwives, clinical nurse specialists, CRNAs, clinical psychologists and clinical social workers (cannot bill for psychotherapy services that include medical evaluation and management services) and registered dietitians or nutrition professionals.
Eligible facilities: Medicare limits the originating sites (where the patient is located) eligible for telehealth-delivered services to the following:
- Provider offices, hospitals, critical access hospitals, rural health clinics, federally qualified health centers, skilled nursing facilities, community mental health centers,
Synchronous is REAL TIME activities such as chat rooms, video conferencing and telephonic conversation. Asynchronous is data transferred to be reviewed later, letters, emails, patient notes, x rays.
Modifiers:
There are three modifiers that can be used for telehealth options: GT, GQ and 95.
- GT modifier – via interactive audio and video telecommunications systems (synchronous telecommunications.
Scenario: Suzy has concerns about a suspicious mole on her arm. She has scheduled an appointment but would like to change the visit to a telehealth visit. Suzy meets with the physician for a 15-minute video conference follow up call. How would this be billed?
- Virtual visit performed with synchronous telecommunications with an existing patient meeting the 15 minutes and 2 of 3 key components. It would be coded 99213-GT POS 2
- GQ modifier – via asynchronous telecommunications system. modifier indicates that telehealth services were performed via an asynchronous telecommunications system (store and forward medical information to be reviewed by the physician or practitioner at the distant site at the convenience of the healthcare providers. This is limited to Alaska and Hawaii when Medicare is billed for non “face-to-face” telehealth services. Report the appropriate code for the professional service with modifier GQ Via an asynchronous telecommunications system.
- 95 modifier – synchronous telemedicine service rendered via real-time interactive audio and visual telecommunications system is a new modifier and NOT recognized by Medicare or Medicaid but some payers require it for claims payment.
Reference: AAPC Telehealth Modifiers GT and GQ
Reference: 7 Essential Rules for Medicare Telehealth Services.
Place of Service (POS)
- Use POS 2 – defined as the location where health services and health-related services are provided or received through a telecommunication system.
Facilities:
- Medicare will pay a facility fee to the facility acting as the originating site using HCPCS code Q3014 t0 receive a separate Part B payment.
Telehealth Facts:
Embracing telehealth options is key as it is on the rise as options for patients and providers. In 2018, the global telehealth market was $49.8 billion and expected to reach $266.8 billion by 2026 according to Fortune Business Insights.
March 6th President Trump signed a spending bill that lifted Medicare’s restrictions on telehealth reimbursement so all beneficiaries have access to telehealth options regardless of their locations. Payers are also evaluating options to encourage virtual visits such as waiving co-pays to allow for more access to their members.
2020 e-visit Online Digital Codes
As a reminder CMS finalized 6 new CPT codes for e-visits. These codes provide new opportunities for physician practices to be reimbursed when conducting digital health assessments and evaluations for established patients.
99421 – online digital evaluation and management service, for an established patient, cumulative time during the 7 days; 5-10 minutes.
99422 – online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 11-20 minutes.
99423 – online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 21 or more minutes.
HCPCS code G2061: qualified nonphysician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the 7 days; 5-10 minutes.
HCPCS code G2062 – qualified nonphysician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the 7 days; 11-20 minutes.
HCPCS code G2063 – qualified nonphysician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the 7 days; 21 or more minutes.
What is an e-visit? It is a non-face-to-face patient initiated digital communication that requires a clinical decision that otherwise would have been provided in the doctor’s office. These codes are intended to over short-term (up to 7 days) evaluations and assessments that are conducted online or via some other digital platform.
If visits go beyond the 7-day maximum remote patient monitoring may be considered. To learn more about these codes refer to: The Nixon Law Group: CMS Introduced Remote Patient Monitoring Codes.
Who can bill for e-Visit Codes? CPT 99421-99423 may be used by physicians and other health care practitioners that can directly bill E/M codes. Non-physician or mid-levels who may not directly bill but do perform these visits may use HCPCS codes G2061, G2062 and G2063.
Established patient a requirement. In order to bill for an e-Visit, the patient must be established in that the provider must have an existing relationship with the patient. Established is determined by state law but usually requires a full examination of the patient’s current condition and medical history.
As always check your contracts and your payers as requirements may vary from payer to payer. In addition, payers are responding by waiving copays, co-insurance, etc. Reference: AHIP: Health Insurance Companies Respond to COVID 19
Additional references:
United guide how to bill Telehealth
CMS Proposes to Modernize Medicare Advantage, Expand Telehealth Access for Patients
What the Coronavirus pandemic means for the telehealth industry