Added 6/9/2021

Q: How long will the public health emergency (PHE) last?

A: Currently, the PHE is set end on July 20, 2021. However, in a letter to governors earlier this year the Biden Administration indicated that the PHE will likely remain in place through the end of 2021. The letter also indicated that providers would get a 60-day notice before the PHE ends to help prepare for a smooth transition.

Q: Since most states are “getting back to normal”, can we still offer telehealth visits under the public health emergency guidelines?

A: Since the PHE is still in place, ALL flexibilities still apply just as they did in 2020 during the height of the pandemic. You can offer telehealth visits to patients at home, via phone if necessary and on any non-public platform (e.g., Facetime, Zoom, Skype are ok, but Facebook Live and TikTok are not. 

Q: Has CMS changed any of the codes lately that can be used during the COVID emergency?

A: CMS has made several changes to the Telehealth Approved List during the course of the public health emergency. The latest additions were made on 4/30/2021. It is always a good idea to check the CMS website frequently for changes. You can find the CMS Telehealth Approved List here.

Q: Have commercial payors stopped covering cost sharing all together? 

A: Most commercial carriers stopped covering cost shares in 2020. If fact, we advise that you contact your top 5-6 commercial payors to see what they are and are not covering for telehealth. For example, a payor may have different coverage guidelines for traditional sick visits versus behavioral health, or they may have different end dates or coverage for their different plans. 

UPDATED 1/6/2021

Q: What are the documentation rules for telemedicine visits?

A: There aren't any specific rules about documenting telemedicine or telehealth services during the current public health emergency, but the general principles of documentation should be your guide. Remember that medical necessity should be documented, and you should include the following:

• Notation that patient consented to the consult held via audio with video or telephone only

• Names of all people present during a telemedicine visit and their role

• Chief complaint or reason for telehealth visit

• Relevant history, background, and/or results

• Clinically relevant examination

• Assessment

• Plan and next steps

• Total time spent on medical discussion

UPDATED 1/6/2021

Q: How can we meet a level 4 or 5 new patient visit with the examination?

A: You can document any elements of exam that you inspect or assess through direct observation. Any examination element that requires “hands-on” the patient (palpation, auscultation, etc.) should not be reported. A comprehensive examination requires at least 8 organ systems be documented, and the examination should be performed according to clinical necessity.

That said, for codes 99202-99215 the 2021 E/M Guidelines for new and established patients would now apply. Therefore, the exam would not “count” toward your E/M code level. Although an examination is not required to calculate the level of service a clinically appropriate examination should be documented to support medical necessity and for continuum of care of the patient.

UPDATED 1/6/2021

Q: I am a physical therapist with an NPI. Since I can bill under my name which codes do I use for Online Digital Visits?

A: Physical therapists, occupational therapists, and speech-language pathologists should use the e-Visit codes (98970-98972 for all payors. Although PTs, OTs, and SLPs do have an NPI, they do not bill E/M visits so they should not use (99421-99423). Medicare and most payors are now allowing for PTs, OTs, and SLPs to bill for therapy services under the telehealth waiver for dates of service March 1st through the remainder of the current pandemic. Check with your commercial payors regarding these rules.

PTs, OTs, and SLPs can also bill for telephone codes 98966-98968 as well as virtual check-ins G2250 and G2251 (new for 2021). For E-Visits, telephone assessments, and virtual check-ins, append therapy modifiers GO, GP, or GN as appropriate.

UPDATED 1/6/2021

Q: I heard there is a new diagnosis for COVID-19. If so, what is it?

A: Effective April 1, 2020 use U07.1 for COVID-19.

• For all dates of service prior to April 1st, use B97.29 Other corona virus as the cause of diseases classified elsewhere, with any respiratory condition listed as primary.

• There are six new diagnosis codes effective January 1, 2021 in light of the ongoing public health emergency. They are as follows:

• Encounter for screening for COVID-19 (Z11.52)

• Contact with and (suspected) exposure to COVID-19 (Z20.822)

• Personal history of COVID-19 (Z86.16)

• Multisystem inflammatory syndrome (MIS) (M35.81)

• Other specified systemic involvement of connective tissue (M35.89)

• Pneumonia due to coronavirus disease 2019 (J12.82)

UPDATED 1/6/2021

Q: What’s the difference between G2012 Virtual Check-In and an (99421-99423) Digital Online Visits? They look the same to me.

A: G2012, G2052, G2250 and G2251 are virtual check-in visits to see if a patient needs to have an E/M service.

Online digital visits (E-visits) are non-video E/M visits that use the patient portal or secure email for the entire visit. Neither of these are telemedicine visits, see definition of a telemedicine visit above.

UPDATED 1/12/2021

Q: Is the HHS pandemic end date still October 23, 2020?

A: No, Secretary Azar of Health and Human Services has extended the current public health emergency (PHE) through April 20, 2021.

UPDATED 10/9/2020

Q: Do we have to use start and stop times or can we use minutes when billing by time?

A: For CMS and some payors exact minutes documented within the permanent record are sufficient, as there is no indication that start and stop times are required for telemedicine visits. You can use start and stop times if you prefer, as long as they are both documented for the visit and are legible.

Some commercial carriers (BCBS and Aetna as of today) want start and stop times documented within the record, according to the latest telehealth guidelines.

ADDED 7/20/2020

Q: Do we add modifier 95 to telephone calls now they are on the CMS approved telehealth list?

A: It depends on the payor and on the MAC. For all Medicare claims the answer is yes, except for First Coast Service Options Inc. First Coast published (in writing) they do not want modifier 95 on telephone claims. For all other payors - review their policies or contact them for further instruction.

ADDED 7/20/2020

Q: Will the upcoming final rule expected in July give us an end date for CMS telehealth coverage?

A: Secretary Azar of Health and Human Services (HHS) determines the end date of the current public health emergency (PHE), not the Final Rule. 

ADDED 6/1/2020

Q: If a telehealth visit (real-time audio with video visit) is started and connection is lost or poor, and the rest of the visit is performed by a phone call only – how should we bill this?

A: Medicare clarified this billing scenario on 5/27/2020, saying to bill the code that reflects the bulk of the visit. Meaning that if 5 minutes was spent on a phone call, then 15 minutes spent on the phone to complete the visit, you would bill a 99442 for the 20 minutes, as the bulk of the visit was via the phone.

UPDATED 6/1/2020

Q: What are the new Medicare specimen collection codes for COVID-19, when the test is sent out to a lab?

A: For dates of service March 1, 2020 through the end of the current COVID-19 pandemic, Medicare will cover specimen collection when the test is obtained and sent out to a separate laboratory for processing, when testing is the only service performed on that day. If an E/M service is performed then the specimen collection code is not separately billable as it is considered part of the E/M service.

If specimen collection is the only billable service performed, for Medicare patients you can bill 99211 (for either a new or established patient) for the specimen collection. Some commercial carriers may prefer you use 99000 Specimen collection. Check with your carrier to see which code is billable.

Codes used by laboratories only for collection: G2023 specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), any specimen source

G2024 specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), from an individual in a SNF or by a laboratory on behalf of a HHA, any specimen source

For a list of the approved codes for COVID-19 testing, see the Coding COVID-19 Testing chart under "Coding Tools & Helps Downloads".

UPDATED 6/1/2020

Q: Our billing company is telling us that Medicare is allowing us to bill E/M codes for telephone only visits. Can we just bill an audio only (telephone visit) with Medicare’s telehealth E/M codes?

A: On April 30, 2020, Medicare added telephone calls (99441-99423) to the approved telehealth services list, however, they are not a replacement for a telehealth E/M (real-time audio and video) visit codes (99201-99215). They clarified that you should bill for 99441-99443 (for physicians, NPs, and PAs) or 98966-98968 (for other qualified healthcare providers) when performing a telephone E/M visit.

Medicare decided to add telephone calls temporarily to the telehealth approved list because some patients don't have access or don't know how to use technology for a virtual face to face visit. They have also increased the wRVU and allowable for 99441-99443 to match the values of 99212-99214 to better reflect the work involved. Telephone calls can be billed for new patients as well as established patients.

So - yes telephone calls can now be billed to Medicare with codes 99441-99443 or 98966-98968 depending on the provider type.

UPDATED 6/1/2020

Q: Are telephone calls the same as telemedicine visits?

A: While telephone calls are now on the telehealth approved list for Medicare, they are not the same as a telemedicine (Medicare calls them telehealth) visits. A telemedicine visit requires both audio and video capabilities in real-time, unlike a telephone call that does not have video capabilities. However, for dates of service March 1st and after, telephone call codes (99441-99443 and 98968-98969) are now a Medicare covered telehealth service temporarily during this public health emergency. Telephone calls are now a reimbursable service when the patient either does not have access to technology or doesn’t have the skill set to use the technology needed for a telehealth visit. Don’t forget to append modifier 95 to the telephone call code since these codes are covered telehealth services during the pandemic.

UPDATED 6/1/2020

Q: What codes can be used for telehealth visits?

A: Any code in the CPT with a gold star (★) can be used as telemedicine/Medicare telehealth visit. Appendix P in the CPT book also has a listing of codes available. This list includes 99201-99215. That said, there are many more codes allowed now during the public health emergency and the CPT book does not list them all. CMS has 251 codes that can be billed as a telehealth visits during the temporary current public health emergency. The CMS published listing is available at https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.

UPDATED 6/1/2020

Q: Have the guidelines for telemedicine been relaxed regarding "seeing" a patient if the provider is not licensed in the state in which the patient currently resides? (i.e., can a doctor licensed in state A see a patient currently residing in state B?)

A: Yes - the guidelines for seeing patients in another state have been temporarily relaxed during the COVID-19 public health emergency. We suggest contacting your state's regional telehealth center for state-based guidance on this. There has been no end date set as of yet, but be mindful that these changes are temporary. And remember that this temporary flexibility does not apply to any state laws. Be sure and check with any state that you may be seeing patients in before seeing or serving in these areas.

Here is a website that provides a summary of the licensure requirements: https://www.fsmb.org/siteassets/advocacy/pdf/state-emergency-declarations-licensures-requirementscovid-19.pdf

UPDATED 6/1/2020

Q: Do we need a special COVID-19 modifier on our claims to get them paid?

A: It depends – for all telehealth services listed on the CMS Telehealth Services list, you will need to add modifier 95 to the line item on the claim. Other payors may have different modifier requirements, so check with the individual payor.

If the visit qualifies as a no cost-sharing visit, then modifier CS is needed. For dates of service March 18, 2020 through the end of the current public health emergency (date to be determined), Medicare is waiving all cost-sharing for COVID-19 testing and any visits (Medicare telehealth visits and digital online visits only) where COVID-19 testing is ordered or performed. If the visit results in the testing or ordering of a test for COVID-19, use modifier CS to indicate that testing was performed or ordered, and Medicare will pay at 100% of the fee schedule allowable. Cost-sharing is not waived for Virtual Check-In or visits for any other diagnosis or condition. For claims on or after March1st (during the current public health emergency) Medicare advises the use of modifier 95 on all telehealth visits when the visit would have normally been performed face-to-face. This modifier only applies to codes considered telehealth. The complete listing by CMS can be found at https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.

However, Medicare clarified on 5/27/2020 that modifier CR is not required on any telehealth claim.

Many commercial payors have modifier requirements to indicate the service was provided via telemedicine. See Payor Telehealth Policies for more information.

UPDATED 6/1/2020

Q: We cannot locate a response from any reliable coding resource about how to bill telephone calls lasting more than 30 min. Do you have any guidance on this topic?

A: Telephone calls for both new and established patients have been temporarily added to the approved telehealth list for Medicare for the duration of the COVID-19 public health emergency. Although these codes have been added as telehealth services, they are not billable with the prolonged services codes (99354-99355 for office patients and 99356-99357 for hospital patients). There is no way to bill for additional time with telephone calls. And as a reminder, time calculated should only include the time for the billing provider talking to the patient, not staff time talking to the patient. Commercial payors may have different billing flexibilities during this crisis, so you will want to check with your commercial payors.

Medicare answered this question in their Q &A from 5/27/2020 and affirmed our answer above that there is not a way to bill for phone calls over 30 minutes.

UPDATED 6/1/2020

Q: Can we bill telephone calls to Medicare now that we can’t see the patient face- to- face because of COVID-19?

A: For dates of service March 1st and after, telephone calls (99441-99443 and 98968-98969) are now a Medicare covered service temporarily during this public health emergency. And, the wRVU and reimbursement for telephone calls (99441-99443) has been increased to the values of 99212-99214 respectively.

And as a reminder code G2012 is available for telephone Virtual Check-In calls.

UPDATED 5/1/2020

Q: Can we bill telemedicine visits by time alone?

A: Yes, for Medicare patients the code set 99202-99215, it is appropriate to bill by time. Telemedicine visits can be billed by either MDM or time alone. Medicare updated their policy and will now use the times for each of these codes that are published by the AMA in CPT 2021. Of course, medical necessity is the overarching criterion for all visits and documentation of exact minutes and any clinically appropriate history and examination should be documented in the permanent patient medical record. Contact other payors for guidance on whether or not billing by MDM or time alone is acceptable.

UPDATED 5/1/2020

Q: Can we bill by MDM or Time for hospital services (initial admits and rounds) listed under new Telehealth list of codes?

A: No. Medicare only allows the use of medical decision making (MDM) and time for 99201-99215 office and other outpatient visits when choosing a level of service. But there are several things to remember when choosing a code from the 99202-99215 range:

Time includes the billing provider’s time only on that date including time such as to review imaging studies or outside records (not staff time)

Greater than 50% of time spent in counseling and/or coordination of care is not required for choosing a telehealth visit level (for 99202-99215 only)

CMS time calculations are now the same as the CPT times listed for each code (see below chart)

MDM definition did not change – criteria to meet is still the same

UPDATED 5/1/2020

Q: Can we bill telephone only (99441-99443) calls subsequently during the week (or the same day) for the same patient by the same provider or another provider of the same specialty within the practice if each call is documented properly?

A: Telephone calls have been added to the approved telehealth list for Medicare during the current COVID-19 public health emergency. According to the CPT Assistant, telephone E/M visits:

• can only be billed once every 7 days by a single provider or other providers of the same specialty within the same practice (meaning you can bill the telephone call code once per practice per week with providers of same specialty)

• can only include time for the billing provider (performing provider(s) if more than one of the same specialty in the same group practice), not staff time on calls

• cannot be billed during the post-op global period for a related issue to any procedure/surgery performed

• can be billed during the post-op global period for an unrelated issue (not a complication) to the procedure or surgery performed (with modifier 24)

• cannot be billed in conjunction with anticoagulant management codes 99363 and 99364 if the call is about warfarin management

• cannot be billed "with the domiciliary, rest home, or home care plan oversight services codes (99339-99340) or the care plan oversight services codes (99374-99380) if the call time is used in reporting the care plan oversight service."

For multiple phone calls during the same day with the same patient, you can aggregate the minutes for the calls and bill ONE telephone call code IF ALL of the following criteria are met:

1. Time calculated is only the time the billing provider is talking to the patient, not nurse or staff time talking to the patient.

2. Time in exact minutes is documented in the chart for EACH call.

3. Documentation for each call indicates what was discussed, changed, or added to the plan of care and reason why (if known) for multiple calls (patient is confused, etc.).

4. Remember - medical necessity for billing any service to Medicare or other payors is based on medical necessity.

5. For multiple phone calls during a 7 day period with the same patient, you would aggregate the minutes for the calls and bill ONE telephone call code if all the above criteria are met.

UPDATED 4/17/2020

Q: What documentation is needed to bill for a phone only visit besides time?

A: There aren't any specific rules about documenting telephone calls for covered telephone call services during the current public health emergency, but the general principles of documentation should be your guide. Remember that medical necessity should be documented, and you should include the following:

• Notation that patient consented to the consult held via telephone

• Names of all people present during a telemedicine consultation and their role

• Chief complaint or reason for telephone visit

• Relevant history, background, and/or results

• Assessment

• Plan and next steps

• Total time spent on medical discussion

UPDATED 4/9/2020

Q: Where can I get comprehensive information about telehealth?

A: KarenZupko and Associates, Inc. (KZA) has a telehealth webinar available on demand and other tools available at http://www.karenzupko.com/KZA-telehealth-solution-center. If you require additional assistance, our consultants are here to help. Contact our office at (312) 642-5616 or email information@karenzupko.com for more information.

UPDATED 4/9/2020

Q: I heard that Medicare patients don’t have to pay their deductible or co-insurance if they have a telemedicine visit. Is this true?

A: For all dates of service March 18, 2020 through the end of the current public health emergency, Medicare is now waiving all cost-sharing for COVID-19 testing and visits where COVID-19 testing is ordered or performed, when a modifier CS is on the claim.

This means that Medicare will pay at 100% of the allowable fee schedule for COVID-19 testing and visits associated with COVID-19 testing. In order to receive payment at 100% coverage for these visits, modifier CS is required on the claim. This change applies to Medicare telehealth visits (commonly performed 99202-99215) and Digital Online visits only. Virtual Check-In is not included and will continue to be paid at the usual rate of 80% of the allowable fee schedule.

For all other covered telehealth visits Medicare is still allowing providers to waive any patient cost-share (e.g., co-insurance, deductible) at their discretion without penalty. This means the provider will only be reimbursed what Medicare pays, if the provider chooses to waive the patient portion of the visit. Many other payors are waiving cost-sharing for telemedicine visits. See Payor Telehealth Policies for more information.

UPDATED 04/9/2020

Q: CMS is saying “E-visit” but not describing a telemedicine visit. Are they the same?

A: CMS is referencing digital online E/M visits (99421-99423) when they refer to “E-visits” in their correspondence. This could change as telehealth evolves, so make sure to look at the codes referenced in the document or alerts you are reading to make sure the definitions or wording they are using has not changed.

UPDATED 4/9/2020

Q: Do you perceive that the spirit of 1135 Waiver which allows providers to waive coinsurance applies to Virtual Check-Ins and/or E-visits as well as Telehealth visits?

A: No. In the Medicare FAQs dated March 17, 2020, they specifically say that the flexibility for providers to waive or reduce cost-sharing to the patient is for telehealth visits only. Virtual Check-Ins and Digital Online Services (E-visits) are not telemedicine and the cost-sharing waiver does not apply to those services. However, on April 7, 2020, Medicare is now waiving all cost-sharing for Online Digital (Evisits) if COVID-19 testing is ordered or performed. They are waiving the cost share for the visit and testing (with the use of modifier CS on applicable line items), but this is only for telehealth visits and digital online services, not for Virtual Check In.

UPDATED 4/9/2020

Q: Have you seen any advisement for providers doing initial evaluations of Nursing Home patients during this crisis? While the established relationship may have been waived, the specific codes are not listed on the List of Telehealth Services. Would G042x be applicable?

A: CMS has updated their list of telehealth services with over 80 new temporarily approved services, and New Patient Nursing Home services (99327-99328) and Established Patient Nursing Home services (99334-99337) are now on the list. Here is the link to the most up to date listing https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.

UPDATED 4/9/2020

Q: Why would I want to waive the Medicare 20% if the patient has does not have secondary coverage?

A: The benefit is to the patient, not to the practice. Medicare will reimburse 80% of the allowable and 20% of the allowable will transfer to the patient. If the practice waives the 20% because of financial hardship to the patient (meaning the patient can’t afford to pay), the patient benefits but the practice has a negative financial impact.

KZA recommends normal billing processes at this time. If there is a financial hardship and the patient responsibility begins aging, decisions may be made. Take the time now to create a COVID-19 financial payment policy.

NOTE: For all dates of service March 18, 2020 through the duration of the current COVID-19 crisis, Medicare is waiving all cost- sharing for all COVID-19 testing and visits where a COVID-19 test is ordered or performed. Providers must add the modifier CS to the claim, and Medicare will reimburse at 100% of the allowable amount for the telehealth or digital online service (Evisit). This only applies to COVID-19 testing and testing related visits.

ADDED 4/9/2020

Q: Can a Registered Nurse (RN) bill G2012 when communicating with a Medicare patient regarding further evaluation?

A: No, G2012 is not billable by a nurse because a nurse is not a credentialed Medicare provider. Although phone calls are now a covered Medicare benefit, they are only billable by the physician or non-physician provider (PA, NP, CNS) who can bill Medicare for an E/M visit. These services cannot be billed "incident to", since the CPT code requires a physician or non-physician provider.

Check with your commercial payors for payor specific guidance.

UPDATED 4/1/2020

Q: Can a nurse bill a 99211 as “incident to” for a telemedicine visit?

A: If all the “incident to” rules are met and the physician and nurse are in the same suite, yes. Or if all “incident to” rules are met and the nurse and patient are in the same location (office or patient home) and the physician is on a real-time audio with video call then this would also be a billable visit.

UPDATED 4/1/2020

Q: When can we start coding telehealth visits?

A: CMS made the telehealth changes retroactive for Medicare for all dates of service after March 1, 2020. For all other payors, see the Payor Summary chart on our site for published payor specific dates.

UPDATED 4/1/2020

Q: Are G2010-G2012 or 99421-99423 considered telemedicine?

A: No, these codes are not considered telemedicine (no gold star in the CPT). Rather, they are e-visits and virtual check-ins. The distinction is:

• Telehealth visits (or telemedicine) allows a clinician (physician, physician assistant, nurse practitioner) to provide a real-time interactive visit via video-chat – that includes both audio and video. Despite CMS adding some therapy codes to the list of covered telehealth services, PTs, OTs, and SLPs are still not eligible to conduct telehealth visits under Medicare.

• E-visits are patient-initiated online digital services for new and established patients (e.g. online patient portal). They are represented by CPT codes 99421- 99423 (0.43-1.39 RVUs) for physicians, physician assistants, and nurse practitioners and CPT codes G2061-G2063 (0.34-0.94 RVUs) for other qualified health providers (PTs, OTs, SLPs) and require a modifier GO, GP, or GN on the claim. These services are not considered telemedicine and are not subject to the previous site limitations.

• Virtual check-ins allow new and established patients to briefly connect with their clinicians (as defined above) between visits where the communication is not related to a medical visit within the previous 7 days and does not lead to a medical visit within the next 24 hours (or soonest appointment available).

These check-ins can be provided by phone, secure text, portal; 5-10 minutes of medical discussion (G2012 for 0.41 RVUs) or remote evaluation of recorded video and/or images submitted by a patient including interpretation with follow- up with the patient (G2010 for 0.34 RVUs). Both codes can be performed by other qualified health providers (PTs, OTs, SLPs) and require a modifier -GO, -GP, or -GN on the claim.

These services are not considered telemedicine and are not subject to the previous site limitations.

UPDATED 4/1/2020

Q: If PA is seeing a patient in the office, could they still bill a Telemedicine visit under physician as “incident to” if they are not at the same site? Did CMS waive the ‘direct supervision’ guideline during this pandemic?

A: If the performing provider is an NPP (physician assistant, nurse practitioner), we advise billing direct under the NPP’s provider number as billing “incident to” a physician by an NPP has not been formally addressed to date. Remember, the guidelines for “incident to” billing are rather stringent so we typically recommend NPPs regularly bill direct for their services. Billing direct by the NPP will help better utilize their talents as well as provide an opportunity to optimize reimbursement because both the physician and NPP can see patients in tandem.

UPDATED 4/1/2020

Q: If the provider is working remotely from home (temporarily), what would the place of service (POS) be?

A: If billing telemedicine visits (with real-time audio and video) then the POS would be the place of service where the provider would have normally seen the patient (office, or hospital-based clinic, etc.) for Medicare and the address on the claim would be the provider's home address, not the clinic address. Once the provider returns to the clinic he/she can perform telehealth visits and would resume using the clinic address on the claim. That is the CMS requirement for Medicare.

For example, if you would normally have seen the patient in your private practice office then report the E/M code using POS 11. If you would normally have seen the patient in a provider-based clinic in the hospital, then report the E/M code using POS 22.

Don’t forget that Medicare now requires modifier 95 (Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications System) to be appended to all CPT codes reported for telehealth visits.

Commercial payors may or may not follow Medicare guidelines. See Payor Telehealth Policies for more information.

UPDATED 4/1/2020

Q: We are doing all our telemedicine encounters in our normal exam rooms. The physician and PA are in the same suite. Are we able to bill “Incident-to” then?

A: If the performing provider is an NPP, we advise billing direct under the NPP’s provider number as billing “incident to” a physician by an NPP has not been formally addressed to date. This will help utilize the NPP and provide an opportunity to optimize reimbursement as both the physician and NPP can see patients in tandem.

UPDATED 4/1/2020

Q: We are performing Virtual Check-Ins and Online Digital Visits. Our place of service will be 11. May we bill “Incident-to” now if the provider is in the office?

A: If all “incident to” guidelines are met, then these visits could be billed as “incident to.” Remember new patients, new problems or any changes in the plan of care do not meet “incident-to” guidelines. All visits are patient-initiated and the scheduling staff may not be able to determine if the encounter meets the billing rules. If the performing provider is an NPP, we advise billing direct under the NPP’s provider number as this has not been formally addressed to date.

UPDATED 4/1/2020

Q: What is the place of service for telemedicine visits?

A: For Medicare, on all claims for dates of service March 1, 2020, and forward through the duration of the current public health emergency, use the place of service code where the provider would have normally performed the face-to-face service (e.g., 11, 22, 19, etc.). For example, if you would normally have seen the patient in your private practice office then report the E/M code using POS 11. If you would normally have seen the patient in a provider-based clinic in the hospital, then report the E/M code using POS 22.

If you normally would have performed the service as a telehealth visit, then use place of service code 02. Commercial payors may have different requirements. See Payor Telehealth Policies for more information.

Q: What is the place of service for Virtual Check-Ins and Digital Online Visits?

A: Use your normal clinic place of service (e.g., 11, 22, 19) as these codes are not recognized as telemedicine.

ADDED 3/26/20

Q: Do we have to use modifier “CR” on professional claims during this public health emergency?

A: Not for Medicare claims. CMS clarified this on March 20, 2020, saying modifier CR is not needed under the current blanket waiver. This is a Medicare modifier, but you may want to verify with your commercial payors.

ADDED 3/26/2020

Q: How do we bill for Q3014 when we perform a telemedicine visit with video?

A: Q3014 is not billed by the provider performing the visit (real-time audio and video) when the patient is at a different location. Q3014 is only billed by facilities if a patient goes to a facility and uses the facility’s technology (computer/web service, room) to have a visit with a provider at a distant site (another location – not on the same campus).

ADDED 3/26/2020

Q: Is a physician clinic considered a facility for telehealth?

A: Yes, as long as the patient is at a different physical location than the billing provider. Meaning – the patient can’t be in the same clinic or site as the doctor performing the telemedicine (or telehealth as Medicare calls it) visit.

ADDED 3/26/2020

Q: Is a physician clinic only an originating site under the COVID-19 government waiver?

A: No. A physician clinic has always been an approved originating site (where the patient is located for a telemedicine visit) and that should not change once the waiver has been lifted. However, remember the patient must be at a different physical location than the provider (physician or PA/NP) in order to qualify for a telemedicine/telehealth visit.

ADDED 3/26/2020

Q: I heard there are tools that CMS has for general practitioners. Do you know where to find this?

A: CMS developed two tool kits and can be found through the following links:

Toolkit for general Telemedicine:

https://www.cms.gov/files/document/general-telemedicine-toolkit.pdf

Toolkit for ESRD providers:

https://www.cms.gov/files/document/esrd-provider-telehealth-telemedicine-toolkit.pdf

ADDED 3/26/2020

Q: What’s the difference between “telehealth” and “telemedicine”?

A: Colloquially, the terms tend to be used interchangeably. By definition, telehealth is a collection of technological tools/services, and telemedicine is an audio/video, real-time E/M visit where the provider and patient interact and communicate. CPT has indicated with a gold star (★) codes that can be used with telemedicine. Modifier 95 is defined as “synchronous telemedicine service rendered via a real-time interactive audio and visual telecommunications systems”. However, Medicare refers to “telemedicine services” as the umbrella of services that include “telehealth visits,” “virtual check-ins,” and “e-Visits.”

ADDED 3/26/2020

Q: Do all the new rules for telemedicine visits apply to Medicaid, since it’s a government payor?

A: Medicaid payors fall under individual state authority so they may have different rules or guidance for telemedicine. Check with your state Medicaid carrier for guidance.

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Q: Is G2012 for telephone calls or just for the patient portal?

A: Keep in mind that G2012 is not a telemedicine visit but rather a “virtual check-in” service. It is not a telemedicine service because it is not performed with real-time audio and video means. If you are indeed performing a “virtual check-in” visit rather than a telemedicine visit, then G2012 would be appropriate. G2012 can be used for a telephone call (no video) or via the patient portal. This code has been described by CMS as communication to see if a patient needs to make an appointment for further evaluation, not as an E/M service in and of itself.

ADDED 3/26/2020

Q: What does Medicare mean by “soonest available appointment” in the definition of G2010-G2012?

A: CMS did not give a specific definition for this. Use your reasonable judgment for what your practice would normally say is your “soonest available appointment”.

ADDED 3/26/2020

Q: Can smartphones be used for telemedicine visits?

A: Yes as long as you are using real-time audio AND video capability. This is true during the temporary waiver enacted by the government. An end date for this service has not yet been established.

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Q: Does telemedicine require special credentialing?

A: No there is no special credentialing required. If you are a provider who can bill E/M services to Medicare under normal circumstances, then you can bill with telemedicine codes.

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Q: Now that we aren’t limited to HIPAA compliant software, can we use any app or platform to conduct a telemedicine visit?

A: You may use any app or platform that is not “public-facing” according to HHS. Platforms such as Facebook Live, Twitch, and TikTok are considered public-facing. Skype, FaceTime, Facebook Messenger Chat, and Google Hangouts video are all approved platforms.

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Q: Can we bill a telemedicine visit if the patient is in the waiting room behind the glass and the physician is in his office at the time?

A: No. Telemedicine visits are only to be used when the patient is not at the same site as the physician.

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Q: Do we have to document in the chart, or keep separate records for telemedicine visits?

A: Documentation rules for services rendered have not changed. All documentation for telehealth services should be documented with appropriate detail in the permanent medical record.

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Q: Can we do telemedicine visits through our EHR?

A: Check with your EHR vendor on this. Some offer telehealth services through their system.

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Q: Can post-op visits be billed as telemedicine visits?

A: No. Post-op visits are still post-op visits if they are within the global period. If you are seeing the patient for an unrelated (not a complication) problem, then a telemedicine visit can be billed with modifier 24. However, you can see post-op patients via a telemedicine platform and report 99024 as you normally would.

ADDED 3/26/2020

Q: Can Medicare post-op visits be billed as remote check-ins where the patient sends a picture of the incision?

A: No. Guidelines for post-op visits have not changed. Since the check-in is related to the surgery, this is not a billable scenario unless it is outside of the surgical global period.