More Telehealth Changes Announced by CMS

April 2nd, 2020 - Wyn Staheli, Director of Research
Categories:   CPT® Coding   Modifiers   HCPCS Coding   Evaluation & Management (E/M)   Medicare   Medicaid  
0 Votes - Sign in to vote or comment.

On March 31, 2020, CMS announced further changes to their telehealth program in response to this unprecedented public health emergency (PHE). The announcement included far more information than is presented in this article which only summarizes the changes to telehealth.

Place of Service and Modifiers

Earlier in March, Medicare began to cover telehealth services for patients in any geographic location. Typically, telehealth services would be billed with Place of Service (POS) code 02 and no modifier. However, the new instructions state to NOT use POS 02 and use modifier 95 instead. They state the following (emphasis added) about which POS to use:

“To implement this change on an interim basis, we are instructing physicians and practitioners who bill for Medicare telehealth services to report the POS code that would have been reported had the service been furnished in person.”

Note: The interim rule states that this change is for Medicare claims. Watch for further instructions from other payers who may follow their lead. 

Additional Services

The following services have temporarily been added to their list of covered telehealth services as of March 1, 2020:

If you have questions about any of these services, please review the complete interim rule “Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency” listed in the References below.

Temporary Evaluation and Management Changes for Level Selection

In regards to Evaluation and Management (E/M) services, CMS noted “We expect physicians and other practitioners to use the E/M code that best describes the nature of the care they are providing, regardless of the physical location or status of the patient.”

To help support E/M services rendered via telehealth, according to the interim rule, Medicare is temporarily allowing EM services to be reported based on Medical Decision Making (MDM) or Time. They stated (emphasis added):

“Under the waiver issued by the Secretary pursuant to section 1135(b)(8) of the Act, telehealth office/outpatient E/Ms can be furnished to any patient in their home regardless of their diagnosis or medical condition. However, the current E/M coding guidelines would preclude the billing practitioner from selecting the office/outpatient E/M code level based on time in circumstances where the practitioner is not engaged in counseling and/or care coordination.

On an interim basis, we are revising our policy to specify that the office/outpatient E/M level selection for these services when furnished via telehealth can be based on MDM or time, with time defined as all of the time associated with the E/M on the day of the encounter; and to remove any requirements regarding documentation of history and/or physical exam in the medical record.”

Interestingly, this is pretty similar to (but slightly different than) the changes that will be coming into effect for E/M office visits beginning on January 1, 2021. Please note that this change applies only to Medicare. Since it just recently happened, watch for announcements from other payers or call their provider relations department to see if they are following this change in reporting requirements for telehealth office visits.

NOTE: To assist providers in understanding the 2021 changes, we have training and books which will be made available during the year. Click here for more information..

Frequency Limitations Revised

According to the “Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19” publication, they have also changed limits on how often the following services may be billed:

  • A subsequent inpatient visit can now be furnished via Medicare telehealth more often than once every three days (99231-99233)
  • A subsequent skilled nursing facility visit can now be furnished via Medicare telehealth more than once every 30 days (99307-99310)
  • Critical care consult codes may be furnished to a Medicare beneficiary by telehealth beyond the once per day limitation (G0508-G0509)
ALERT: These are not ALL the changes to telehealth — just those that have changed since their previous announcements. The interim rule also includes many other changes beyond the telehealth information listed above.

###

Questions, comments?

If you have questions or comments about this article please contact us.  Comments that provide additional related information may be added here by our Editors.


Latest articles:  (any category)

How to Combat COVID-Related Risk Adjustment Losses with the Medicare Annual Wellness Exam
April 12th, 2021 - Aimee Wilcox, CPMA, CCS-P, CST, MA, MT, Director of Content
Identifying new ways to encourage Medicare beneficiaries to schedule and attend their Annual Wellness Exam (AWE) can be difficult, but the Open Enrollment period is a prime time for every payer to identify new beneficiaries and provide a reminder to both new and existing patients that this preventive service does ...
Failure to Follow Payer’s Clinical Staff Rules Costs Provider $273K
April 12th, 2021 - Wyn Staheli, Director of Research
Clinical staff (e.g., LPN, RN, MA) provide essential services which allow providers to leverage their time and improve reimbursement opportunities and run their practices more efficiently. There is, however, an ongoing question of how to appropriately bill for clinical staff time. This is really a complex question which comes down to code descriptions, federal or state licensure, AND payer policies. Failure to understand licensing and payer policies led a Connecticut provider organization down a path that ended in a $273,000 settlement with both federal and state governments.
Properly Reporting Imaging Overreads (Including X-Rays)
April 8th, 2021 - Aimee Wilcox CPMA, CCS-P, CST, MA, MT and Wyn Staheli, Director of Content Research
hile many provider groups offer some imaging services in their offices, others may rely on external imaging centers. When the provider reviews images performed by an external source (e.g., independent imaging center), that is typically referred to as an overread or a re-read. Properly reporting that work depends on a variety of factors as discussed in this article.
How Social Determinants of Health (SDOH) Data Enhances Risk Adjustment
March 31st, 2021 - Aimee Wilcox, CPMA, CCS-P, CST, MA, MT, Director of Content
The role of SDOH in overall patient care and outcomes has become a more common topic of discussion among healthcare providers, payers, and policymakers alike. All are attempting to identify and collect SDOH and correlate the data to patient management which is increasingly seen as necessary to address certain health disparities and identify exactly how SDOH affects patient health outcomes. Learn how to address this important subject.
Understanding Skin Biopsy Codes
March 23rd, 2021 - Christine Woolstenhulme, QCC, QMCS, CPC, CMRS
A biopsy is a procedure to obtain only a portion of a lesion for a pathologic exam. According to the AMA, "The use of a biopsy procedure code (e.g., 11102, 11103) indicates that the procedure to obtain tissue for pathologic examination was performed independently, or was unrelated or distinct from other ...
How Reporting E/M Based on Time May Lose Money
March 18th, 2021 - Aimee Wilcox, CPMA, CCS-P, CST, MA, MT, Director of Content
Just like math teachers who require students to show their work so they can see how the student reached their answer, providers are also required to "show their work" through the documentation process in the medical record. By the time a provider has reviewed the patient's subjective complaints (i.e., patient's ...
COVID-19 Vaccines
March 10th, 2021 - Christine Woolstenhulme, QCC, QMCS, CPC, CMRS
To accommodate the new COVID-19 immunizations the CPT editorial panel has approved 11 Category I codes. Watch for new and revised guidelines and parenthetical notes with these codes. For example; which administration codes should be used with the vaccine codes and the NCD codes applicable to the dose being administered. These ...



Home About Contact Terms Privacy

innoviHealth® - 62 E 300 North, Spanish Fork, UT 84660 - Phone 801-770-4203 (9-5 Mountain)

Copyright © 2000-2021 innoviHealth Systems®, Inc. - CPT® copyright American Medical Association