New Communication Technology-Based Services (CTBS) Codes for Nonphysicians

Medicare continues to expand the number of services provided via technology. There are some interesting new codes for nonphysician practitioners (NPPs) (e.g., psychologists, physical therapists) that became effective on January 1, 2021. Communication Technology-Based Services (CTBS), also known as virtual check-ins, describe specific short provider-patient communications which are initiated by the patient.

Medicare allows the following to be billed by practitioners who cannot independently bill for E/M services as long as it is “consistent with the scope of these practitioners’ benefit categories:”

• G2250 Remote assessment of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment
• G2251 Brief communication technology-based service, e.g. virtual check-in, by a qualified health care professional who cannot report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment; 5–10 minutes of medical discussion

Last year, codes G2010 and G2012 were added to describe similar ‘check-ins’ rendered by a physician or QHP to determine whether or not an office visit was necessary. Now, to further promote coordinated patient care, virtual check-ins may be provided by NPPs with these new codes. Although originally proposed to only be utilized during the COVID-19 Public Health Emergency (PHE), they are no longer restricted to use during the PHE.

Tip: According to CMS, patient consent to provide CTBS services may be documented by auxiliary staff under general supervision as well as by the billing practitioner. Unlike other telehealth services, there are not the same “timing or manner” restrictions on when that consent is obtained.

Similar to codes G2010 and G2012, the following restrictions apply:

• Must be an established patient
• Must NOT be related to an E/M visit that occured in the previous 7 days or will occur within 24 hours or the next available appointment

For services provided by therapists (physical, occupational, speech), these are considered “sometimes therapy” services as noted in the following statement from the Medicare Physician Fee Schedule Final Rule:

“...we are finalizing our proposal to designate HCPCS codes G2250, G2251, G2061, G2062, and G2063 as ‘‘sometimes therapy’’ services to facilitate billing of the CTBS by therapists. Additionally, we note that when billed by a private practice PT, OT, or SLP, the codes would need to include the corresponding GO, GP, or GN therapy modifier to signify that the CTB are furnished as therapy services furnished under an OT, PT, or SLP plan of care.”

Note: There was a statement in the MPFS final rule which stated that CMS is replacing G2061-G2063 with codes 98970-98972 “for [a] qualified nonphysician health care professional online digital E/M service.” Read code descriptions carefully to ensure reporting the most appropriate code to describe the service provided.

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