KZA Telehealth Solutions Center

An up-to-date, comprehensive resource regarding
the ever-changing telemedicine guidelines.

Please note that we update materials as changes are made by CMS. Please check back.

*We strongly encourage that you bookmark or save this page for easy access
in the future and check back regularly for updates as we learn more.

FAQs

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.


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.

FAQs

Last updated on 6/1/2020 at 10:00PM

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.

Coding

UPDATED 4/9/2020

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. If the patient has been exposed to a confirmed COVID-19 case use Z20.828 Contact with and (suspected) exposure to other viral communicable diseases. If the patient is concerned about possible exposure but this is ruled out after an examination, use Z03.818 Encounter for observation for suspected exposure to other biological agents ruled out.

If the visit is not related to COVID-19, then only use the applicable diagnosis codes for that visit.


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 99201-99215) 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 4/9/20

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 is for a virtual check-in visit 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 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.


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


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.”


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.


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.


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”.


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.


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.


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.


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.

Place of Service

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.

Telephone Only

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 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.


Post-op Visits

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


And here are the approved codes for COVID-19 testing:

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 286 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 5/1/2020

Q: Can we bill telemedicine visits by time alone?

A: Yes, for Medicare patients the code set 99201-99215, 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 2020. 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: 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 or for Medicare G2061-G2063). 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 G2010 and G2012. In all three scenarios of e-Visits, telephone assessments, and virtual check-ins, append therapy modifiers GO, GP, or GN as appropriate.


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 99201-99215 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
  • 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

---PREVIOUSLY POSTED FAQs---

Coding

---NEW FAQs---

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. 

Telephone Only

Documentation

UPDATED 6/1/2020

Q: What are the documentation rules for telemedicine visits?

A: Medicare now says that the appropriate E/M code for the telehealth visit (real-time audio and video) may be chosen based on Medical Decision Making (existing guidelines – not the new 2021 guidelines) or total amount of time. This is good news for surgeons who oftentimes must choose a lower level E/M code because the Examination component is not met. Be sure to have good documentation of the MDM or time – whichever you use to choose the level of billed E/M code. Check your other payors for their policies.


As a reminder, you may still choose the code by the 1995 or 1997 traditional guidelines if you prefer. The new flexibility for using either MDM or time is for the benefit of the provider, since a comprehensive examination is difficult to meet under the traditional guidelines. 


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 4/1/20

Q: How can we do an examination on a patient through the internet or on a smartphone?

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.


That said, CMS now says that the E/M code (e.g., 9920x, 9921x) may be chosen based on Medical Decision Making (current version) or time (total time spent with the patient). Therefore, the exam would not “count” toward your E/M code level at this time. Check your other payors for their policies.


UPDATED 6/1/2020

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 to be documented, and the examination should be performed according to clinical necessity.


That said, CMS now says that the E/M code (e.g., 9920x, 9921x) may be chosen based on Medical Decision Making (current version) or time (total time spent with the patient). Therefore, the exam would not “count” toward your E/M code level at this time. Check your other payors for their policies.


UPDATED 6/1/2020

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

A: 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.


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.


Q: Can we do telemedicine visits through our EHR?

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


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 FAQs---

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.


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

CMS Makes Major Changes to Telehealth 

Consents


Medicare now says that annual patient consent does not have to be obtained prior to the initial telehealth visit. Consent should not interfere with patient care and can be obtained during or after the visit if necessary.


Virtual Check-In and E-visits


Virtual Check-Ins (G2010-G2012) and E-visits (G2061-G2063) can now be performed for both new and established patients.


Virtual Check-Ins (G2010-G3012) and E-visits (G2061-G2063) can now be billed by LCSWs, clinical psychologists, PTs, OTs, and SLPs if needed. CMS also requires that therapists use the appropriate therapy modifier (GO, GP, GN) for their services.


Physician Supervision


CMS has temporarily augmented the definition of direct physician supervision to include virtual supervision. During the current public health emergency, the provision requires that the physician use real-time audio with video technology while supervising.


Frequency Limitations

There are now no frequency limitations on the following:

  • Subsequent inpatient visit (99231-99233) not limited to once every 3 days
  • Subsequent skilled nursing visit (99307-99310) not limited to once every 30 days
  • Critical care consult codes (G0508-G0509) not limited to once per day


Provider Enrollment and Other Temporary Regulatory Changes

There is now a temporary waiver for both Medicare and Medicaid that no longer requires providers be licensed in the state where the patient is seen as long as the provider meets the following 4 criteria:

  1. The provider is already enrolled in the Medicare program, and
  2. The provider must have a valid license to practice in the state listed on Medicare enrollment, and
  3. The provider caring for patients (in person or telehealth) in a State is to contribute to relief efforts in his or her professional capacity, and
  4. Is not excluded from practice in the State or any other State that is part of the area identified by the 1135 waiver.


CMS has established toll-free hotlines to simplify and expedite provider enrollment. See MAC information at
https://www.cms.gov/files/document/provider-enrollment-relief-faqs-covid-19.pdf


To see other regulatory changes see the Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19 article at
https://www.cms.gov/files/document/covid-19-physicians-and-practitioners.pdf

CMS Makes Major Changes to Telehealth

UPDATED JUNE 2, 2020

Telehealth Covered Codes


For dates of service March 1, 2020 through the end of the current pandemic, Medicare has approved 286 codes on the temporary telehealth services list. Here are some commonly used categories:

  • Telephone Calls
  • Audiology Services
  • Behavioral Health
  • Other Therapy Services

In addition to these newly added codes, CMS states that they will consider “add[ing] new telehealth services on a sub-regulatory basis” as providers learn to navigate and request new services that can potentially be performed via telehealth.


For a complete listing go to Complete CMS Telehealth Covered Services.


New Audio-Only Provision for Certain Telehealth Services


In keeping with provider concerns voiced about challenges in using real-time audio with video technology within the Medicare population, CMS now allows several services to be performed using only a telephone without any video component. Column D “Can Audio-only Interaction Meet the Requirements?” in the Complete CMS Telehealth Covered Services list indicates this change. Most codes are from the following categories:

  • Telephone calls
  • Prolonged Services
  • Various G codes for telehealth consults and counseling
  • Behavioral health

While these services can now be performed via the telephone only, the integrity of the visit, clinical relevance, intent, and documentation requirements remain the same. And as always, medical necessity is the overarching criterion for each visit.


Higher Payment for Telephone Only E/M Services


After many concerns and a lot of feedback from providers, Medicare is increasing payment for the Telephone E/M codes 99441-99443 considering that these services would otherwise have been reported as in-person or telehealth visits. Since “other qualified healthcare providers” (e.g., physical therapists, occupational therapists, speech language pathologists) do not bill E/M services, codes 98966-98968 were not considered in the revaluing process. The following wRVU and pricing changes are retroactive to March 1, 2020.

ALERT!!!!!!!!

Do not bill 99201-99215 for telephone only E/M, as these codes still require real-time audio and video.

Times Associated with Telehealth E/M Services


Medicare also made changes to the published times they require when billing for telehealth visits that would normally be billed as office visits outside of the current pandemic. Previously, Medicare had a different standard of time than what the AMA had published in the CPT. Effective for all claims on or after March 1, 2020, Medicare will use the standard times for codes 99201-99215, as they are listed in the CPT to avoid any additional confusion when choosing a telehealth visit by time. Medicare will now use the CPT standards for time-based billed of these telehealth services as shown in the table below.

Changes in Non-Physician Practitioner Utilization


Medicare is also changing the way certain NPPs can be utilized, giving them greater flexibility within their scope of practice as designated by state law. Nurse practitioners, clinical nurse specialists, and physician assistants can now supervise diagnostic tests performed under their supervision. Historically, supervision of diagnostic testing was allowed only by physicians. NPPs also now have the authority to provide the following home health services:


  • Ordering of home health services
  • Establishing and periodically reviewing the Plan of Care for Medicare beneficiaries
  • Certifying and re-certifying patient eligibility for Home Health Services


PTs, OTs, and SLPs and Telehealth Services

Medicare is now allowing physical therapists, occupational therapists, and speech language pathologists the ability to perform and bill telehealth services. This is a big win for orthopedic practices as therapy is an area that has been greatly impacted by the current pandemic. This will allow for Medicare patients to receive and/or resume a treatment plan during the current public health emergency.


Medicare is also allowing physical and occupational therapists the authority to “delegate maintenance therapy services to physical and occupational therapy assistants in the outpatient setting.” This is to allow physical and occupational therapists the ability to perform other duties that help Medicare patients receive care.


Physician Order No Longer Needed for COVID-19 Testing


Medicare is no longer requiring a physician order from a treating physician or other practitioner for beneficiaries to have a COVID-19 test. Medicare also announced they are “covering certain serology (antibody) tests”, to see if the patient has developed an immune response.


For an in-depth listing and explanation of all Medicare changes on April 20, 2020, see the following press release at https://www.cms.gov/newsroom/press-releases/trump-administration-issues-second-round-sweeping-changes-support-us-healthcare-system-during-covid.

Updated April 9th - but all these changes are still in effect to date. 

Medicare Waiver of Patient Cost-Sharing


For dates of service March 18, 2020, through the end of the current COVID-19 public health emergency, Medicare will waive all patient cost-share for COVID-19 testing and any telehealth visits where COVID-19 testing is ordered or performed. This applies to approved outpatient telehealth visits, hospital telehealth visits, and digital online E/M (Evisits). This change does not include Virtual Check In visits, as these services will continue to be paid at 80% of the allowable fee schedule, with a 20% patient cost share.


In order to get paid at 100% of the Medicare allowable fee schedule, the modifier CS should be used on the claim line item for either the COVID-19 test, telehealth visit, or both.


Remember to document the clinical relevance of why the testing was performed and that the test was either ordered to be performed at another facility, or ordered and performed during the visit.


For all other Medicare approved telehealth services, Medicare is allowing providers to waive the patient’s cost-share (deductible and/or coinsurance) 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 payors are waiving cost-sharing for telemedicine visits. See Payor Telehealth Policies for more information.


Telehealth Covered Codes


For dates of service on or after March 1, 2020, CMS has temporarily relaxed many regulations around providing telehealth care for patients. They have added over 80 codes which include, but not limited to, the following NEWLY ADDED categories pertinent to surgical practices. Visit the CMS website for a complete listing of codes.


  • 99281-99285 Emergency Department Visits
  • 99218-99220 Initial Observation, 99224-99226 Subsequent Observation, 99217 Observation Discharge Day Management, and 99234-99236 Same Day Observation
  • 99221-99223 Initial hospital care and 99238-99239 Hospital discharge day management
  • 99291-99292 Critical Care Services
  • 99468-99476 Inpatient Neonatal and Pediatric Critical Care Initial and Subsequent
  • 99477-994780 Neonatal/Low Birth Weight Initial and Continuing Intensive Care Services
  • 97161- 97168; 97110, 97112, 97116, 97535, 97750, 97755, 97760, 97761, 92521- 92524, 92507 Therapy Services, Physical and Occupational Therapy


Place of Service (POS) on the Claim

There are TWO major new points:


  1. Effective March 1, 2020, during the COVID-19 public health emergency, use the place of service where the provider would normally have performed the visit if the patient had been seen face-to-face (e.g. 11 or 22), NOT POS 02 for all CMS telehealth and telephone services. 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.
  2. And append modifier 95 (Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications System) for all telehealth services on Medicare claims. This allows Medicare to pay these visits at the higher Non-Facility fee schedule rate. CMS does allow providers to continue to use POS 02 for all telehealth services, however, this will result in decreased reimbursement under the Facility Fee Schedule. Commercial payors may have different guidelines, so check with your respective payors on this.

    TIP: File corrected claims for telehealth services that have already been billed to update the place of service. You might want to hold on to your non-Medicare claims for a few days to see if these payors will now follow Medicare’s new guidelines.


Choosing an Outpatient/Office E/M Code (99201-99215) – MDM or Time

Medicare now says that the appropriate E/M code for the telehealth visit (real-time audio and video) may be chosen based on Medical Decision Making (existing guidelines – not the new 2021 guidelines) or total amount of time. This is good news for surgeons who oftentimes must choose a lower level E/M code because the Examination component is not met. Be sure to have good documentation of the MDM or time – whichever you use to choose the level of billed E/M code.


The Patient’s Home as Site of Service

The patient’s home is now an approved site and all facilities are now approved sites as originating sites. There are no site or geographical limitations for the patient or the provider for telehealth visits. That said, you will NOT use a POS 12 (Home) on your claim. Just know that Medicare has relaxed the rules requiring a more formal originating site during this time of public health emergency.


If the provider is furnishing the telehealth service from their own home, list the provider’s home address in Box 32 service location on the claim. The POS code is still where you normally would have seen the patient such as POS 11 for physician office or POS 22 for HOPD.


Telephone Only Services – Medicare Now Pays 99441-99443 and 98966-98968!

Telephone only E/M visits are now approved for new and established patients. These codes were previously non-covered and not payable by Medicare. But at this time due to the COVID-19 pandemic, Medicare will reimburse for these services. Additionally, while CPT states these codes are for established patients, Medicare is allowing telephone only E/M codes for new patients.


Physicians and NPPs (e.g., physician assistant, nurse practitioner) that bill under their own NPI should use 99441-99443 while “qualified non-physician health care professionals” such as registered dieticians, social workers, speech-language pathologists, and physical and occupational therapists should use codes 98966—98968. CMS also requires that therapists use the appropriate therapy modifier (GO, GP, GN) for their services.

Telehealth
Reference Guide 

UPDATED 5/1/2020

This article has been updated to reflect sweeping changes made by CMS on April 30, 2020 and prior to that on March 30, 2020. This guide covers the temporary changes made due to the COVID-19 public health emergency (PHE). In order to accommodate the increased demand for patient care while protecting patients and healthcare workers, several key updates have been made. The following information is effective for all dates of service on or after March 1, 2020. At this time there is no end date for these changes, as the PHE is an ongoing event.

Definition of Telehealth and Telemedicine

The terms telehealth and telemedicine 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."

Telemedicine Technology

Effective March 17, 2020, the Office for Civil Rights (OCR) will not impose penalties for noncompliance with the HIPAA Rules in connection with the good faith provision of telehealth during the COVID-19 emergency, regardless of the patient’s diagnosis.


PLEASE NOTE: Separate State action will be required in certain areas – physicians should assess their State-specific privacy laws prior to moving forward.


Where to get started?


Platform selection. CMS allows for use of telecommunications technology that has audio and video capabilities that are used for two-way, real-time interactive communication to conduct Telehealth visits. Which one to use?

  • Does your EHR vendor offer a Telehealth option? Is it readily available? Realistically how quickly could it be operationalized?






 

  • During the period of time of the national emergency, CMS is temporarily waiving the enforcement of using HIPAA compliant platforms. Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype are all options*.   

    Physicians are encouraged to notify patients that these third-party applications potentially introduce privacy risks, and physicians should enable all available encryption and privacy modes when using such applications.

    Another practical consideration – would personal contact information be shared with patients? FaceTime uses a cell phone number, Facebook Messenger video chat uses a Facebook account. A business Skype account could be utilized.

    * NOTE: Facebook Live, Twitch, TikTok, and similar video communication applications are public-facing, and should not be used in the provision of Telehealth.

Equipment Needs. A smartphone will have a built-in camera. Most laptops and many tablets have a built-in camera and microphone. If you will be conducting the visit at a desktop, do you have a webcam and a microphone?


Operational Considerations

  • Telehealth informed consent. Contact your medical malpractice carrier or your specialty society about obtaining a specific Telehealth informed consent (Here’s an example: https://www.thedoctors.com/siteassets/pdfs/risk-management/informed-consent-forms/Telehealth.pdf).

  • Documentation template for telehealth visits. An example provided to us states: “Patient seen today via Telehealth by agreement and consent of patient in light of current COVID-19 pandemic. I used the following Telehealth technology ___________________________________ (e.g., video, phone call) during the visit. This patient encounter is appropriate and reasonable under the circumstances given the patient’s particular presentation at this time. The patient has been advised of the potential risks and limitations of this mode of treatment (including but not limited to the absence of in-person examination) and has agreed to be treated in a remote fashion in spite of them. Any and all of the patient’s/patient’s family’s questions on this issue have been answered and I have made no promises or guarantees to the patient. The patient has also been advised to contact this office for worsening conditions or problems, and seek emergency medical treatment and/or call 911 if the patient deems either necessary.”

  • Scheduling. If the office is closed, scheduling telehealth visits would likely follow the same patterns as scheduling in-office visits. However, take a look at how your appointment schedule is ultimately linked to the claim that is generated as the place of service for telehealth may be different (as discussed later).

    For those practices who are still seeing patients in the office, managing telehealth visits with in-person visits needs to be considered. It’s likely easier to create a separate appointment type of “Telehealth” to distinguish them from regular visits. Further consider creating different appointment types for “telehealth visit,” “telephone visit,” “e-Visit,” and “virtual check-in.” Also, keep in mind any scheduling reporting/appointment counts you may want to do later. Think of the scheduling set-up from the perspective of all staff – those who will be scheduling the appointments, those who will be “rooming” the patients, the providers, and how it impacts billing.

  • Patient Flow. Determine what patient flow will look like. Where will you physically conduct the Telehealth visit? In an exam room? At your desk? Will you be at home? Who will get the patient “ready” to be seen?

  • Tech Troubleshooter. Who will be your designated troubleshooter? Inevitably, patients will need some tech help, so proactively assign a tech-savvy staff member to assist.
  • Payment collection. It’s a delicate time right now. Medicare is allowing, but not requiring, coinsurance and deductible amounts to be waived. Some payors have eliminated cost-sharing requirements for telehealth visits. See the Payor Summary chart for details. For patients who have patient responsibility amounts, perhaps a prudent choice is to allow for online payments and/or sending the patients a bill for the services after the telehealth visit.


Billing Considerations

What kind of visit is it?

There are four kinds of services that can be performed remotely during the public health emergency (PHE). The type of modality used (audio+visual, phone, patient portal) is the driving determination of what kind of visit it is.

Telemedicine visits typically have the highest reimbursement, followed by e-visits, telephone visits, and virtual check-ins. When determining which services to provide virtually, consider cost, resources, technology, continuity of care, and reimbursement for those services.  

Place of Service (POS)

There are two major new points:


Effective March 1, 2020, during the COVID-19 public health emergency, use the place of service where the provider would normally have performed the visit if the patient had been seen face-to-face (e.g. 11 or 22), NOT POS 02 for all CMS telehealth and telephone services. For example, if you would normally have seen the patient in your private practice office then report the Evaluation and Management (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 via telehealth means, then use POS 02 on the claim.


And append modifier 95 (Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications System) for all telemedicine visits on Medicare claims (no modifier 95 on e-Visits, virtual check-ins, and telephone calls as these services are not telemedicine.) This allows Medicare to pay these visits at the higher Non-Facility fee schedule rate when applicable. CMS does allow providers to continue to use POS 02 for all telehealth services, however, this will result in decreased reimbursement under the Facility Fee Schedule. Commercial payors may have different guidelines. For all other payors, see the Payor Summary chart on our site for published payor guidelines.


TIP: File corrected claims for telehealth services that have already been billed to update the place of service. You might want to hold on to your non-Medicare claims for a few days to see if these payors will now follow Medicare’s new guidelines.


If the provider is furnishing the telehealth service from their own home, list the provider’s home address in Box 32 service location on the claim. The place of service is still the same place of service the provider would normally see the patient (office, or hospital-based clinic, etc.) and the address on the claim would be the provider’s home address, not the clinic address.

Choosing an Outpatient/Office E/M Code (99201-99215) – MDM or Time

Medicare now says that the appropriate E/M code for the telehealth visit (real-time audio and video) may be chosen based on Medical Decision Making (existing guidelines – not the new 2021 guidelines) or total amount of time. This is good news for surgeons who oftentimes must choose a lower level E/M code because the Examination component is not met. Be sure to have good documentation of the MDM or time – whichever you use to choose the level of billed E/M code.

Modifiers

95: Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications System: Note: Medicare now temporarily requires modifier 95 on all claims for telehealth visits that would normally be performed as face-to-face visits such as an office visit.


GQ: Via asynchronous telecommunications system. Clinicians participating in the federal telemedicine demonstration programs in Alaska or Hawaii must submit the appropriate CPT or HCPCS code for the professional service along with the modifier GQ “via asynchronous telecommunications system.”


For other telehealth modifiers see the KZA Modifier matrix above on the web page.


Note: Medicare stopped the use of modifier GT (Via interactive audio and video telecommunication systems) in 2017 when the place of service code 02 (Telehealth) was introduced. However, many private payors are still using the modifier GT. See the Payor Summary chart for reference.  

Physician Supervision

CMS has temporarily augmented the definition of direct physician supervision to include virtual supervision. During the current public health emergency, the provision requires that the physician use real-time audio with video technology while supervising.

Originating Site

During the COVID-19 public health emergency, rural and site limitations are removed. Home is temporarily an approved site (during the COVID-19 pandemic). Telehealth services can now be provided regardless of where the enrollee is located geographically and regardless of the type of facility.


Physicians do not report Q3014 (Telehealth originating site facility fee). This code is used by an originating site separate from where the physician is located when performing traditional telehealth services pre-public health emergency rules. Refer to the above discussion on place of service (POS) codes.


Note: Locations that are newly eligible will not receive a facility fee.

Telephone Only Services – Medicare Now Pays 99441-99443 and 98966-98968

Telephone only E/M visits are now approved for new and established patients. These codes were previously non-covered and not payable by Medicare. But at this time due to the COVID-19 pandemic, Medicare will reimburse for these services. Additionally, while CPT states these codes are for established patients, Medicare is allowing telephone only E/M codes for new patients.


Physicians and NPPs (e.g., physician assistant, nurse practitioner) that bill under their own NPI should use 99441-99443 while “qualified non-physician health care professionals” such as physical and occupational therapists, speech-language pathologists, registered dieticians, and social workers should use codes 98966—98968. CMS also requires that therapists use the appropriate therapy modifier (GO, GP, GN) for their services


ALERT: Do not bill 99201-99215 for telephone only E/M, as these codes still require real-time audio and video. Some private payors allow the billing of 99201-99215 for telephone only service. Check your individual payor policies for guidance.

Virtual Check-In

G2010 Remote evaluation 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 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


G2012 Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report E&M 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


Consider the following guidelines when billing the below codes:

  • Can now be billed by PTs, OTs, SLPs, LCSWs, and clinical psychologists, if needed. CMS also requires that therapists use one of the following modifiers for these services: GO, GP, or GN
  • Can be any real-time audio (telephone), or "2-way audio interactions that are enhanced with video or other kinds of data transmission"
  • During current public health emergency (PHE) can be a new or established patient
  • Any chronic patient who needs to be assessed as to whether an office visit is needed
  • Patients being treated for opioid and other substance-use disorders
  • If an E/M service is provided within the defined time frames, then the telehealth visit is bundled within that E/M service
  • No geographic restrictions for patient location
  • Should be initiated by the patient since a co-pay is required. Verbal consent to bill and documentation is required
  • Communication can use non-HIPAA compliant technology during the COVID-19 public health emergency
  • Not considered a telemedicine service so does not need modifier 95 for Medicare claims

Online Digital Evaluation & Management (E/M) or e-Visits

99421 Patient-initiated 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 or more minutes

NOT used for: Non-evaluative electronic communication of test results, scheduling of appointments, or other communication that does not include E/M.


Other notes for using 99421-99423 codes:


  • Must be through HIPAA-compliant secure platforms, such as electronic health record (EHR) portals, secure email, or other digital applications
  • During current public health emergency (PHE) can be a new or established patient
  • Performed asynchronously and audio/video phone can be used (not a traditional telephone) 
  • Must be patient-initiated  
  • The patient must be informed and, the information documented in the chart 
  • Cost-sharing applies to the E/M service; deductible still applies 
  • Use only once per 7-day period 
  • Clinical staff time is not calculated as part of cumulative time 
  • Service time must be more than 5 minutes 
  • Do not count time otherwise reported with other services 
  • Do not report on a day when the physician or other qualified health care professional reports E/M services 
  • Do not report when billing remote physiologic monitoring (RPM), Chronic Care Management (CCM), Transitional Care Management (TCM), care plan oversight (CPO), and codes for supervision of patient in home, domiciliary or rest home, etc. for the same communication 
  • Do not report for home and outpatient international normalized ratio (INR) monitoring when reporting 93792, 93793 
  • Not considered a telemedicine service so does not need modifier 95 for Medicare claims 

For healthcare professionals that don’t bill directly to Medicare for E/M services:

Use these codes for Medicare patients only when an online assessment, such as using the patient portal, is being performed by a non-physician profession such as PTs, OTs, SLPs, LCSWs, and clinical psychologists, if needed. CMS also requires that therapists use one of the following modifiers for these services: GO, GP, or GN

G2061 Qualified non-physician professional online assessment (such as using the patient                           portal), for up to 7 days, 5-10 minutes cumulative time during the 7 days 

G2062 11-20 minutes

G2063 21 or more minutes

Remote Monitoring - No change for COVID-19

UPDATED 5/1/2020


99453 Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education on use of equipment


99454 Remote monitoring of physiologic parameter(s) (e.g., weight, BP, pulse oximetry, respiratory flow rate) initial; device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days


99457 Remote physiologic monitoring treatment management services, 20 minutes or more of clinical staff, physician, or other qualified health professional time in a calendar month requiring interactive communication with the patient/caregiver during the month


  • Established or new patients
  • For both chronic and acute conditions
  • Can now be provided if patient has only 1 disease process
  • If monitoring is for treatment of COVID-19 or suspected COVID-19, Medicare allows the service to be reported if more than 2 days and less than 16 days (all other conditions require monitoring of 30 days)
  • Patient initiated
  • Involves "asynchronous transmission of healthcare information" from the patient
  • If an E/M service is provided within the defined time frames, then the telehealth visit is bundled in that E/M service
  • Follow-up can be by phone, audio/video, secure text messaging, email or patient portal communication
  • Should be initiated by the patient since a copay is required. Verbal consent to bill and documentation is required
  • Communication must be HIPAA compliant
  • This is distinct from CCM code 99490, which can be provided without the patient's presence and use any means of communication
  • Not considered a telemedicine service so does not need modifier 95 for Medicare claim

COVID-19 ICD-10-CM Guidance

If you are diagnosing and/or treating a patient with COVID-19 is important to use the appropriate ICD10CM codes. Effective April 1, 2020 use U07.1 for COVID-19 once the patient is diagnosed. Prior to April 1st dates of service use B97.29 Other corona virus as the cause of diseases classified elsewhere, listed secondary with any respiratory condition (examples below) listed as the primary diagnosis.


  • J12.89 Other viral pneumonia
  • J20.8 Acute bronchitis due to other specified organisms 
  • J80 Acute respiratory distress syndrome 
  • J98.8 Other specified respiratory disorders 

If the patient has known exposure, use the applicable exposure codes:

  • Z03.818 Encounter for observation suspected exposure to other biological agents ruled out
  • Z20.828 Contact with and suspected exposure to other viral communicable diseases 

For signs and symptoms outside of any exposure, use appropriate codes:

  • R05 Cough
  • R06.02 Shortness of breath 
  • R50.9 Fever, unspecified 

NOTE: Do NOT use B34.2 (coronavirus infection, unspecified) because COVID-19 would not be unspecified.

Testing for COVID-19

Aesthetic plastic surgery practices: Did you know that Symplast, PatientNow, Modernizing Medicine, Stage4, and Nextech all offer an integrated telehealth platform and/or have preferred vendors? Contact your vendor’s account manager for more details. 

Payor Telehealth Policies

Payor Telehealth Policies

Last Updated May 11, 2020

Created by Cheyenne Brinson

Medicare updated its policy on March 31, 2020. Many commercial payors have updated their policies as well. We will continue to monitor updates to payor policies. Please check back often for updates.

MAY 11, 2020

Telehealth During the Public Health Emergency

Telehealth During the Public Health Emergency

Updated May 13, 2020

Created by Cheyenne Brinson

Flow Chart for Telehealth Billing During the Current COVID-19 PHE

Flow Chart for Telehealth Billing During the Current COVID-19 PHE

Last Updated June 2, 2020

COVID-19 Related Modifiers

COVID-19 Related Modifiers

Last Updated May 20, 2020

Preoperative Visit Scenarios

Preoperative Visit Scenarios

Last Updated April 30, 2020

Coding COVID Testing

New CPT® Codes

for COVID-19 Testing

Up to date as of June 2, 2020

Licensure Requirements

Federation of State Medical Boards (FSMB):
Listing of States Modifying Licensure
Requirements/Renewals for Physicians
in Response to COVID-19

Please click on the Telehealth Licensure Requirements link for the most updated file. 

6 Easy Ways Physicians Can Enhance Your Telemedicine & Video Conferencing Presence

6 Easy Ways Physicians

Can Enhance Your

Telemedicine & Video

Conferencing Presence

By Jennifer O'Brien 

May 20, 2020

Journal of Otolaryngology Article

Embracing telemedicine into your otolaryngology practice amid the COVID-19 crisis: An invited commentary

Kim Pollock, Michael Setzen, and Peter F. Svider


Am J Otolaryngol. 2020 Apr 15 : 102490.

doi: 10.1016/j.amjoto.2020.102490 [Epub ahead of print]


PMCID: PMC7159874

PMID: 32307192

Common Telehealth wRVU  & Allowables 

Common Telehealth wRVU
& Allowables

Updated May 22, 2020

Medicare Payment for COVID-19 Diagnostic Tests

Medicare Payment for COVID-19 Diagnostic Tests

Earlier this year, CMS developed two codes that laboratories can use to bill for certain COVID-19 lab tests, including blood tests. CMS has updated its guidance to include payment details for additional CPT codes created by the American Medical Association. There is no cost-sharing for Medicare patients. You can find your local Medicare carrier allowables here:

https://www.cms.gov/files/document/mac-covid-19-test-pricing.pdf


Meet the Consultants

Kim is a nationally recognized coding expert. Her energetic and engaging teaching style makes her a sought-after educator, trainer and speaker. Her nursing background provides her with the ability to understand both the clinical and coding attributes of a procedure. She is an expert in analyzing chart documentation and in reengineering practices to enhance the reimbursement process. Kim has worked with small and large as well as private and academic and employed practices to provide coding education as well as performed documentation reviews.

Kim Pollock

RN, MBA, CPC, CMDP

Cheyenne is an innovative, solutions-oriented consultant and instructor who delivers pragmatic business solutions that boost revenue, streamline workflow, and increase operational efficiency. “You cannot manage what you do not measure” is Cheyenne’s guiding principle, and she leverages this wisdom to make sound, data-based decisions.

Cheyenne Brinson

CPA (inactive), MBA

Jennifer Bell

MSOLE, CPC, CPMA, CHC

Jennifer Bell (Jen) has over 30 years of experience and accumulated knowledge in prospective and retrospective auditing and coding abstraction. She has delivered both coding and auditing services for a wide range of medical and surgical specialties. Jen’s extensive knowledge and skills in successful appeals and payment recovery processes involving major payors generates positive returns for clients.

If you require additional assistance and would like to schedule a consultation, please email information@karenzupko.com for more information.

KZA Virtual and On-Demand Education

Now is the perfect time to sharpen up your coding and

reimbursement knowledge with education from KZA.

On-Demand Workshops

On-Demand Webinars

Webinar

Telehealth is changing daily and here is what you need to know.

KZA is here to help with these rapid changes.

ATA COVID-19 Response Webinar Series

Complimentary ATA COVID-19 Response Webinar Series: Lessons Learned on Billing in the Age of COVID

“The genie is undoubtedly out of the bottle” according to the results of KZA’s Telehealth Payment Pulse Survey.

Neurosurgeons, Orthopaedic Surgeons, Otolaryngologists, and General Surgeons are the majority of the nearly 300 respondents. Interesting takeaways and intel for you to use.

  • Survey Overview and Key Trends
  • Myth Busters: Four Common Misbeliefs
  • Seven Telehealth Coding Tips
  • Payment Snafus and Denials
  • Closing Insights

Karen Zupko and Jennifer Bell are lively presenters, eager to share the survey results and how they may impact your practice or organization.

©2020 KarenZupko & Associates, Inc., All Rights Reserved