Communication Technology-Based Services Reimbursement Update

Information regarding coding, coverage, and payment is provided as a service to our readers. Every effort has been made to ensure accuracy. However, HMP and the author do not represent, guarantee, or warranty that coding, coverage, and payment information is error-free and/or that payment will be received.

Unfortunately, the COVID-19 Public Health Emergency (PHE) has been extended once again. During this unprecedented PHE, wound/ulcer management professionals have learned to use a variety of digital technologies for communicating with and providing wound/ulcer management assessments to patients who could not/would not risk exposure by having in-person encounters. Thanks to numerous PHE waivers, telehealth services are currently provided to many patients who do not require procedures. Once the waivers end, some of the current telehealth options will not be available. See the February 2021 Business Briefs column for lists of telehealth services 1) that will end when the COVID PHE ends, 2) that will remain in place until the end of the calendar year in which the PHE ends, and 3) that are now permanent telehealth services.

Because patients and wound/ulcer management professionals have become accustomed to telehealth wound/ulcer assessments, there is a lot of “buzz” about how patients can still have similar communications with their physicians and qualified health care professionals (QHPs) when the telehealth waivers end, and the telehealth regulations return.

The most logical answer, for patients who will no longer qualify for telehealth, is communication technology-based services (CTBS) that are not regulated by the telehealth rules. During the PHE, wound/ulcer management professionals may have been too busy to notice that codes, coverage, and payment are now in place for CTBS, or may have chosen not to use CTBS because the Medicare payment for them is lower than for telehealth. This is a great time to review all the CTBS opportunities that exist and to determine if some or all of the services will meet your patients’ needs. Once you determine which CTBS best fit into your practice, you should begin to educate your patients about the CTBS that are available during the PHE and that will continue after the PHE ends. Let us look at some of these CTBS options:

CTBS that can only be provided by physicians/QHPs who can report evaluation and management (E/M) services

•    Audio only E/M services, allowed until the end of the PHE:
   o    99441 for 5–10 minutes
   o    99442 for 11–20 minutes
   o    99443 for 21 or more minutes

•    Virtual check-In services with patients to determine if an E/M visit is necessary, allowed during and after the PHE ends:
   o    G2012 for 5–10 minutes
   o    G2252 for 11–20 minutes

•    Online non-face-to-face digital E/M services for established patients-cumulative time up to 7 days, allowed during and after the PHE ends:
   o    99421 for 5–10 minutes
   o    99422 for 11–20 minutes
   o    99423 for 21 or more minutes

CTBS that can be provided by physicians, QHPs, and therapists because the services are considered “sometimes therapy” services:

•    Nonphysician audio-only services, allowed until the end of the PHE:
   o    98966 for 5–10 minutes of medical discussion
   o    98967 for 11–20 minutes of medical discussion
   o    98968 for 21–30 minutes of medical discussion

•    Nonphysician online digital assessment and management services for established patients—cumulative time up to 7 days, allowed during and after PHE:
   o    98970 for 5–10 minutes
   o    98971 for 11–20 minutes
   o    98972 for 21 or more minutes

   NOTE: These codes replace G2061, G2062, and G2063. Be sure to correct your Charge Description Master and your charge sheets if you have been reporting G2061–G2063.

•    Remote assessment of recorded video and/or images submitted by an established patient, allowed during and after the PHE:
   o    G2250

   NOTE: This code replaces G2010. Be sure to correct your Charge Description Master and your charge sheets if you have been reporting G2010.

•    Virtual check-in services for established patients, allowed during and after the PHE.
   o    G2251

   NOTE: This code replaces G2012. Be sure to correct your Charge Description Master and your charge sheets if you have been reporting G2012.

Interprofessional telephone/internet/electronic health record (EHR) consultations (eConsult), allowed during and after the PHE ends:

Prior to the COVID-19 PHE, physicians could easily have face-to-face consultations with each other in the hospital and/or in their offices. COVID-19 made these consultations more difficult. That is when CTBS eConsults began to flourish. See the August 2020 Business Briefs column for a complete review of these important CTBS options:

•    Treating physician:
   o    99452 for 30 minutes

•    Consulting physician who provides a written report:
   o    99451 for 5 minutes or more of medical consultative time

•    Consulting physician who provides a verbal and written report:
   o    99446 for 5–10 minutes of medical consultative discussion and review
   o    99447 for 11–20 minutes of medical consultative discussion and review
   o    99448 for 21–30 minutes of medical consultative discussion and review
   o    99449 for 31 minutes or more of medical consultative discussion and review

Summary:

By now you are probably making a list of patients (e.g., those with transportation issues, those who must travel long distances, those who wait too long to make an appointment) who could benefit from CTBS. You should carefully plan how to incorporate CTBS into your workflow by engaging your staff, who will be instrumental in implementing the process. Then you should plan how to educate pertinent patients about CTBS. Keep in mind that even though you have a patient portal does not mean that the patients know about it and/or understand how to use it. Remember that telling someone how to use their digital device does not mean they will be able to use the device for a particular purpose. You will need a variety of educational modalities for your patients and everyone on your staff will need to do their part to implement CTBS. At first, the education component may be slow, but the gain for both the patients and the physicians, QHPs, and therapists may be worth it. In a very few months, CTBS will be second nature for everyone who is involved:

•    Patients will be requesting virtual check-ins to learn if an office visit or other service is needed. In those instances, physicians/QHPs will report G2012/G2252 (depending on the length of the visit) and therapists will report G2251 for the virtual check-ins.
•    Patients will be sending videos and/or images of any concerning skin changes. Physicians, QHPs, or therapists will review the items and follow up with the patients within 24 business hours. In those instances, the professionals will report G2250 for the remote evaluations of the recorded videos and/or images.
•    Patients will be requesting online e-visits with their physicians/QHPs. In those instances, the physicians/QHPs will report the e-visit codes depending on the length of the visit: 99421–99423.
•    Patients will be requesting online e-visits with their therapists. In those instances, the therapists will report the e-visit codes depending on the length of the visit: 98970–98972.

When you review the 2021 Medicare Physician Fee Schedule Allowable Rates for CTBS, you may think the rates are low. However, many physicians, QHPs, and therapists have reported that CTBS requires minimal resources, and that they typically handle many CTBS quickly during a dedicated time of day. In fact, this author was quite surprised to see how many CTBS services are completed in one hour. In addition, many wound/ulcer management professionals have reported that CTBS has two main benefits: 1) allows digital communication with patients, and 2) makes more room in the schedule for patients who require face-to-face encounters. Therefore, now is a good time for wound/ulcer management professionals to consider offering CTBS services.

Kathleen D. Schaum is a founding member of the Today’s Wound Clinic editorial advisory board and oversees a consulting business. She can be reached for consultation and questions by emailing kathleendschaum@bellsouth.net.