Updated Coding Guidelines For Non-Face-To-Face Services During COVID-19

Coding continues to change and evolve for the non-face-to-face services we can provide during the COVID-19 public health emergency. As an update to my previous March 23 Podiatry Today blog, I would like to share some of these changes. 

There are four non-face-to-face service types we can perform for most of our patients throughout the COVID-19 Public Health Emergency:

1. telehealth for Medicare Part B and Medicare Advantage patients;

2. a virtual check-in for a Medicare Part B or Medicare Advantage patient (using G2012);

3. telephone evaluation and management services; and

4. online digital evaluation and management services.

On March 30, the Centers for Medicare and Medicaid Services (CMS) released the “Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency” Interim Final Rule.1 In this rule, CMS clarified that it only considers option #1 listed above to be “telehealth.” CMS considers “telehealth” to be a service ordinarily furnished in-person, which one instead furnishes using interactive, real-time audio and video telecommunication technology. Other payors and entities may use the term “telehealth” differently.

There are a variety of other Medicare changes in this rule as well.

• Stop using place of service “02” for Medicare telehealth (option #1 above) and instead use the place of service code you would have used had you rendered the service in person.
• Start using modifier 95 for Medicare telehealth (option #1 above).
• When submitting a claim with the above two guidelines followed, CMS will start paying telehealth (option #1 above) at  non-facility rates.
• Many more evaluation and management types are now eligible for Medicare telehealth (option #1 above) beyond those that are typically performed in the office. These E&M service types include initial and subsequent hospital evaluation and management, initial and subsequent nursing facility evaluation and management, and much more.
• When choosing the level of office/outpatient evaluation and management (CPT 99201-99215) provided via telehealth, (option #1) we can use medical decision making only or total time only.
• CMS will start to pay for telephone evaluation and management services (option #3 above).
• One can provide all of these services for both new and established patients.

Most of the information covered here applies only to CMS. For private insurance guidance, it is important to check with that insurance company.  

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.

References

1. Centers for Medicare and Medicaid Services. Medicare and Medicaid programs; policy and regulatory revisions in response to the COVID-19 public health emergency. Available at: https://hhs.com/assets/docs/covid-final-ifc.pdf . Accessed April 9, 2020.
2. Centers for Medicare and Medicaid Services. Medicare telemedicine health care provider fact sheet. https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet . Accessed April 9, 2020.