Coding Insights On Remote Services You Can Provide During The Coronavirus Outbreak

As of March 20, 2020 there are three options for services podiatrists can provide remotely to patients. 

1. Use CPT 99202-99215 for Medicare Part B and Medicare Advantage patients when providing Evaluation and Management services remotely for as long as the public health emergency lasts.
2. Podiatrists can provide telephone evaluation and management (E/M) services for any insurance patient, but these services are often not reimbursable.
3. Podiatrists can provide online digital E/M services for any insurance patient, but these services are often not reimbursable.

There are also Medicare G codes for “virtual check-ins” but these are likely not as applicable during this public health emergency given the ability to use CPT 99202-99215 when performing these services remotely so I am not including them here. 

For most of us, the first option I listed above is the best option if you have the required communication tool(s) and the patient is a Medicare beneficiary. 

Details for each of the three options are listed below.

Using Office E/M Codes For Treating Medicare Patients Remotely

On March 17, 2020, under the 1135 waiver authority and the Coronavirus Preparedness and Response Supplemental Appropriations Act, the Centers for Medicare and Medicaid Services (CMS) announced that we can submit CPT 99201-99215 when providing these services remotely. We can be in any location and the patient can be in any location. Physicians need to keep the following guidelines in mind.

• One must use a communication tool that has interactive audio and video.
• The communication tool must allow real-time communication. Examples include FaceTime and Skype.
• We are permitted to reduce or waive cost-sharing for these services if we wish.
• Typical HIPAA guidance does not apply to these services as long as we are providing these services in good faith.
• No modifiers are necessary. 
• One would use place of service “02.”

The CMS notes these remote services will be paid at the facility rate and the option to use these E/M codes when performed remotely will be in place as long as the public health emergency lasts. Document a progress note as you normally would. This CMS option can be used for an established patient or a new patient.

For more information, view the CMS Fact Sheet at: https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet .

What You Can And Cannot Do When Reporting Telephone E/M Services

There must be supporting documentation for a telephone E/M service just like any other E/M type of service. This must include a history, as much of an evaluation as you can elicit and some form of medical management. The patient who receives this service must be an established patient and the visit must be initiated by that established patient or his or her guardian.

One cannot report a telephone E/M service in the following circumstances:

• If the call results in a decision to see the patient “within 24 hours or at the next available urgent appointment;”
• If the call is in reference to an E/M service performed by you within the previous seven days;
• If the call refers to a problem for which a patient is in a global period;
• If you performed a telephone E/M or online digital E/M for this same patient for the same problem in the last seven days; or
• If the call is part of home care oversight services, care plan oversight services, home/outpatient international normalized ratio (INR) monitoring, complex care management services or transitional care management services.

The following CPT codes apply for telephone E/M services.

• CPT 99441: Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian not originating from a related E/M service provided within the previous seven 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.
• CPT 99442: Same description as 99441 but with 11-20 minutes of medical discussion.
• CPT 99443: Same description as 99441 but with 21-30 minutes of medical discussion.

Understanding Online Digital E/M Services

As with E/M services provided over the telephone, E/M services provided online must have similar documentation as any other E/M type. This would include patient history, as much of an evaluation as you can elicit and some form of medical management.

Examples of “digital” platforms include HIPAA-compliant EHR, HIPAA-compliant e-mail and other HIPAA-compliant two-way digital communication. The patient must be an established patient and the visit must be initiated by an established patient via a digital platform.

One cannot report an online E/M service in the following circumstances:

• If the call refers to a problem for which a patient is in a global period;
• If the clinician performed a telephone E/M or online digital E/M for the same patient for the same problem in the last seven days;
• If the clinician performed the online E/M service on the same day as in-person E/M service; or
• If the call is part of home care oversight services, care plan oversight services, home/outpatient INR monitoring, complex care management services or transitional care management services.

Time spent is cumulative over seven days starting with the review of the request. This time includes:

• review of inquiry;
• review of patient records;
• interaction with other staff;
• development of a management plan;
• prescribing;
• ordering tests; and 
• communication with the patient.

Add time if multiple providers in the same practice perform this service for the same patient over the same seven-day period. If within seven days of the initiation of an online digital E/M service, a separately reported E/M visit occurs, then the physician’s or other Qualified Health Professional’s (QHP’s) work devoted to the online digital E/M service is incorporated into the separately reported E/M visit.

• CPT 99421: Online digital evaluation and management service for an established patient for up to 7 days, cumulative time during the 7 days; 5-10 minutes
• CPT 99422: 11-20 minutes
• CPT 99423: 21 or more minutes

Current Procedural Terminology (CPT®) copyright 1966, 1970, 1973, 1977, 1981, 1983-2019 by the American Medical Association. All rights reserved. CPT is a registered trademark of the American Medical Association (AMA).  

Dr. Lehrman operates Lehrman Consulting, LLC, is a consultant to the APMA Health Policy and Practice Department, serves as an expert panelist on Codingline, and is a Certified Professional Coder. Follow him on Twitter @DrLehrman.