Author: Jordan Johnson
COVID-19 has caused us all to pivot and think outside the box. One of the biggest opportunities that has quickly been expanded and deployed is telehealth. On Tuesday, under President Trump’s leadership, the Centers for Medicare & Medicaid Services (CMS) broadened access to Medicare telehealth services so that beneficiaries can receive a wider range of services from their doctors without having to travel to a healthcare facility. Telehealth, telemedicine and related terms generally refer to the exchange of medical information from one site to another through electronic communication to improve a patient’s health.
For telehealth, a big question has been what platforms along with the telephone can be used. HHS clarified this yesterday:
Platforms that can be used:
- Apple FaceTime
- Facebook Messenger
- Google hangouts
- Skype
- Zoom
Platforms that cannot be used include:
- TikTok
- Twitch
- Facebook Live
Covered health care providers that seek additional privacy protections for telehealth while using video communication products should provide such services through technology vendors that are HIPAA compliant and will enter into HIPAA business associate agreements (BAAs) in connection with the provision of their video communication products. The list below includes some vendors that represent that they provide HIPAA-compliant video communication products and that they will enter into a HIPAA BAA.
- Skype for Business
- Zoom for Healthcare
- Updox
- me
- Vsee
- Google G Suite Hangouts Meet
It is important to remember that there are “New Patients’ and “Established Patients” Per the HHS and CMS clarifications the following are the CPT® codes to utilize.
Telehealth Visits
| Code | Description | Patient status | Place of service |
|---|---|---|---|
| 99201 - 99205 | Office or other outpatient visit for E&M of new patient | New Patient | Medicare-02 | Modifier 95 for commercial |
| 99211-99215 | Office or other outpatient visit for E&M of established patient | Established | Medicare 02 | Modifier 95 for commercial |
Online Digital Visits
| Code | Description | Patient status |
|---|---|---|
| 99421 | Online digital E&M service, for an established patient, for up to 7 days, cumulative time during the 7 days: 5-10 minutes | Established |
| 99422 | 11-20 minutes | Established |
| 99423 | 21 or more minutes | Established |
| G2061 | Qualified nonphysician health care professional online digital assessment and management, for and established patient, for up to 7 days, cumulative time during 7 days: 5-10 minutes | Established |
| G2062 | 11-20 minutes | Established |
| G2063 | 21 or more minutes | Established |
| G2012 | Brief communication technology-based service, e.g., virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion | Established |
| 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 | Established Patient |
Do not bill the 994441-99443 telephone management codes. These codes are still not covered by Medicare as they retain a status indicator of “N.”
What about these codes?
These are for DOCTOR TO DOCTOR ONLY.
Interprofessional telephone/Internet/EHR consultation is defined in the guidelines as an assessment and management service in which a patient’s treating physician or other QHP requests the opinion and/or treatment advice of a physician with specific specialty expertise (the consultant) to assist in the diagnosis and/or management of the patient’s problem without the need for the patient’s face-to-face contact with the consulting physician. Codes 99446-99449 were revised to include “electronic health record,” and two new codes (99451 and 99452) were established. Code 99451 was established to allow reporting of telephone/Internet/EHR consultation services without a verbal component.
| Code | Description |
|---|---|
| 99446 | Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician, including a verbal and written report to the patient's treating/requesting physician or other qualified health care professional; 5-10 minutes of medical consultative discussion and review. Includes Verbal and written reports from the consultant to the requesting provider. |
| 99447 | Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician, including a verbal and written report to the patient's treating/requesting physician or other qualified health care professional; 11-20 minutes of medical consultative discussion and review. Excludes Prolonged services without direct patient contact (99358-99359). |
| 99448 | Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician, including a verbal and written report to the patient's treating/requesting physician or other qualified health care professional; 21-30 minutes of medical consultative discussion and review. Excludes Prolonged services without direct patient contact (99358-99359). |
| 99449 | Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician, including a verbal and written report to the patient's treating/requesting physician or other qualified health care professional; 31 minutes or more of medical consultative discussion and review. Excludes Prolonged services without direct patient contact (99358-99359). |
| 99451 | Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician, including a written report to the patient's treating/requesting physician or other qualified health care professional, 5 minutes or more of medical consultative time. Includes Verbal and written reports from the consultant to the requesting provider. |
| 99452 | Interprofessional telephone/Internet/electronic health record referral service(s) provided by a treating/requesting physician or other qualified health care professional, 30 minutes. |
Recommendations and suggestions
- As we continue to get updates on telehealth and the utilization here is something important to note—EMR and EHR mapping is critical. These patients will need to be easily identified at a later date. One suggestion is to create a mnemonic for these codes for example if you are using the current 99xxx codes for telehealth/video follow-ups, create new codes in the system for identification. Example:
- 99211TH
- 99212TH
- 99213TH
- 99214TH
- 99215TH
- These should be coded at the departmental level and then crosswalked to the billing office, which will be important later. The name does not matter, simply add an identifier so you can distinguish these codes now and later. This should be looked at being implemented facility-wide.
- What about a facility component or hospital component for these codes? This is difficult and still needs some clarification. When seen on site we always bill G0463- Hospital outpatient clinic visit for assessment and management of a patient.
- There still needs to be a facility code captured. Capture the G0463 and put a special identifier on it in the EMR
- Remember you can code today, but do not have to bill today. Meaning go ahead and perform the work and document it. You do not have to bill it. Timely filing is 12 months for Medicare.
- Documentation is critical. As thing are being done differently and the following may be changing be sure to update the documentation to reflect it:
- IGRT types and frequency
- Fractionation
- Dose
- Cancelations
- Outside collaboration with surgery, med oncs or primary care providers.
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Jordan Johnson
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