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  
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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.

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