Telemedicine and COVID-19 Follow Up – Where Are We Now?

What Does CMS Say? 

Congress passed wavier 1135 that states Medicare and other commercial carriers have temporarily expanded services for reimbursement on several telehealth services.  Click here for list of covered services during this Public Health Emergency (PHE) due to COVID-19.  For additional information on COVID-19, click here. 

CMS is now releasing News Alerts almost daily since March 31st.  One initiative brought forward is Put Patients Over Paperwork.  CMS is temporarily eliminating paperwork requirements and allowing clinicians to spend more time with patients.  CMS will continue to engage in oversight activities but will suspend requesting additional information from providers and healthcare facilities.  Reprioritizing these audit activities will allow CMS and the organizations to focus on patient care.   

CMS is also promoting telehealth services during this time and has expanded access, regardless where the patient is located.  Services now include places like, inpatient rehab facilities, hospice and home health.  Medicare has a video, via YouTube that is 17 minutes explaining the expansion of 1135 wavier and also details clinical, coding and billing information, click here. 

CMS approved additional state Medicaid waivers and amendments to give states flexibility to address the pandemic. For a list of states with 1135 wavier flexibilities, click here. For Medicaid state plan amendments, click here. 

What Does Everyone Else Say? 

 Prior to the pandemic, all states had some coverage of behavioral telehealth services to their Medicaid patients.  However, many providers chose not to provide behavioral telehealth services because of massive inconsistency with commercial payer laws. 

During the PHE, regulation of private payers varies by state.  Some states have required commercial payers to waive copayments for telehealth.  Per Psychiatric Times, “Massachusetts Governor Charlie Baker mandated that health insurers cover telehealth services for all in-network providers, reimburse these services at the same rates as face-to-face encounters, and they cannot require prior authorizations for these services.  Forty-two states have telehealth payer laws pertinent to commercial payers.  The statues and regulations dictate coverage and reimbursement that vary from state-to-state.” 

Latest Guidance: 

• COVID-19 waivers and guidance, and the Interim Final Rule, click here 
• Medicaid telehealth flexibilities for rural health care substance use disorder, click here 
• CMS’ letter to the Clinician, click here 

• Recommendations for non-emergent, elective medical service and treatment, click here 

Billing Telemedicine Codes 

Telehealth Services 

99201 – 99215 

• Use of interactive audio/video must be used and documented 

• Medicare updated the guidelines for code selection to be based on the medical decision making or total time spent in “medical discussion”, which must be documented 
• Provider and patient’s locations 
• Place of service (POS) should be the same as it would have been in the absence of the PHE for services dated on or after March 1st through the duration of the PHE 
• Modifier 95 should be amended to codes 
• Modifier GQ should be amended to codes as part of a federal telemedicine demonstration project in Alaska and Hawaii 

• Modifier GT should be amended to codes when billed under CAH Method II 
• Modifier GO should be amended to codes when services are furnished for purposes of diagnosis and treatment of an acute stroke 

Virtual Check-Ins 

G2012 – Brief communication technology-based service, e.g., virtual check-in, by a 

physician or other qualified health care professional who can 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 an E/M service or procedure within 

the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion 

• Document the mode of communication 
• Patient-initiated encounter 
• Patient’s verbal consent obtained and documented 
• Time spent in medical discussion 

G2010 - A remote evaluation of recorded video and/or images submitted by a patient 

Telephone Visits 

99441 - telephone evaluation and management service by a physician or other qualified health 

care professional who may report evaluation and management services provided to an 

established patient, parent, or guardian not originating from a related E/M service provided 

within the previous 7 days nor leading to an E/M service or procedure within the next 24 

hours or soonest available appointment; 5-10 minutes of medical discussion 

99442 - 11-20 minutes of medical discussion 

99443 - 21-30 minutes of medical discussion 

98966 - Telephone assessment and management service provided by a qualified 

nonphysician health care professional to an established patient, parent, or guardian not 

originating from a related assessment and management service provided within the previous 

7 days nor leading to an assessment and management service or procedure within the next 

24 hours or soonest available appointment; 5-10 minutes of medical discussion 

98967 - 11-20 minutes of medical discussion 

98968 - 21-30 minutes of discussion 

• Document the mode of communication 
• Patient-initiated encounter 
• Patient’s verbal consent obtained and documented 
• Time spent in medical discussion 

E-Visits 

99421 – Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes 

99422 – 11-20 minutes 

99423 – 21+ minutes 

Clinicians who may not independently bill for evaluation and management visits (i.e., PT, OT, SLP, clinical psychologists) can provide these e-visits and bill the following codes: 

G2061 – Qualified non-physician healthcare professional online assessment and management, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes 

G2062 – 11-20 minutes 

G2063 – 21+ minutes