As preventive measures increase to slow the spread of the Coronavirus (COVID-19) many healthcare providers are interested in serving patients remotely while being paid for their services. Two days ago laws changed allowing a temporary expansion of Telehealth Services. This applies to Medicare patients and we are finding that most private insurance carriers and Medicaid carriers are following the same processes.
Prior to March 17th, 2020 Telehealth services could only be provided to Medicare patients in specific situations. This has been changed temporarily to allow clinicians to provide telehealth without regard to the patient location. This is a massive change which allows practices to serve patients without requiring the patient to travel. If the patient or the provider are across state lines there can be complications depending on state requirements.
A range of providers including doctors, nurse practitioners, clinical psychologists, and licensed clinical social workers, will be able to offer telehealth to their patients. If the provider is allowed to bill evaluation and management services they would bill with the same CPT code as if they would have provided the service in the office (more detail below). If unable to provide evaluation and management services they are likely limited to G2061 -G2063. Medicare requires the place of service to be “02” for Telehealth. Medicare does not require the GT modifier but we are seeing that some commercial carriers require it. So far it is our recommendation to include the GT Modifier for Telemedicine if the service was provided via interactive audio and video telecommunications systems.
Here are the services that are now available for Medicare patients. We are also finding that many of these are available to Medicare Advantage, Medicaid, and commercially insured patients.
Medicare Telehealth Visits
A visit with a provider that uses telecommunication systems between a provider and a patient.
Telehealth Visits include 99201-99215 Office or other outpatient visits, G0425-G0427 Telehealth consultations for emergency department or initial inpatient. G0406-G0408 follow-up inpatient telehealth consultations furnished to beneficiaries in hospitals or Skilled Nursing Facilities. For a complete list go to https://www.cms.gov/medicare/medicare-general-information/telehealth/telehealth-codes
Virtual Check-In
Virtual Check-In services include a brief 5-10 minute check in with your practitioner via telephone or other telecommunications device to decide whether an office visit or other service is needed. Or a remote evaluation of recorded video or images submitted by an established patient. G2012 or G2010 (pre-recorded video).
E-Visits
Communication between a patient and their provider through an online patient portal. Codes for this series are 99421, 99422, 99423. These must be for established patients. For G2061, G2062, and G2063 these can be provided by clinicians who may not independently bill for evaluation and management visits (for example – physical therapists, occupational therapists, speech language pathologists, clinical psychologists).
Technology required
Previously in order to provide Telehealth services you would need to have HIPAA compliant software and a Business Associate Agreement (when applicable). The Section 1135 Waiver during this National Health Emergency has has made it easier. The announcement states “We are empowering medical providers to serve patients wherever they are during this national public health emergency. We are especially concerned about reaching those most at risk, including older persons and persons with disabilities”. The announcement also states “a covered health care provider that wants to use audio or video communication technology to provide telehealth to patients during the COVID-19 nationwide public health emergency can use any non-public facing remote communication product that is available to communicate with patients.” (Link to the HHS announcement is below). Another section clarifies that this expansion does not allow use of public facing applications like Facebook Live, Twitch, TikTok, and similar video communication. There is caution that this expansion of HIPAA is Federal and some states have more strict guidelines. We have verified that Oregon defers to the Federal HIPAA Requirements.
Place of Service Address (Box 32)
From what we can find the place of service in the equivalent of Box 32 on a HCFA should be the location where the provider usually renders service. Here is the quote from the National Telehealth Policy Research Center – “based on a a letter exchange between CTeL members and CMS regarding POS 02, CMS indicated that “… practitioners must use the address where they typically practice in Box 32. If they work part of the time out of a clinic and part of the time out of their home, they may use the clinic address. If they work out of their home 100% of the time, as some providers do, they must use their home address.” This is found on page 5 of the PDF at the following link: https://www.cchpca.org/sites/default/files/2020-01/Billing%20Guide%20for%20Telehealth%20Encounters_FINAL.pdf
We are all in this together and the scene is changing daily. If there are questions about how your practice can provide Telehealth services please feel free to contact us.
Here are links so that you can learn more about this massive change for Telehealth.
CMS Press Release Related to Telehealth Expansion: https://www.cms.gov/newsroom/press-releases/president-trump-expands-telehealth-benefits-medicare-beneficiaries-during-covid-19-outbreak
CMS Telehealth Fact Sheet: https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet
CMS Telehealth Frequently Asked Questions March 17, 2020: https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf
CMS List of Telehealth Approved Services: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes
HHS Notice of Enforcement Discretion during COVID19: https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html
HHS OIG COVID-19 Portal: https://oig.hhs.gov/coronavirus/
Oregon Policy for Protected Health Information: https://www.oregonlaws.org/ors/192.553
Physical Therapy and eVisits G2061-G2063 Frequently Asked Questions from the APTA: http://www.apta.org/PTinMotion/News/2020/03/18/E-VisitFAQs/#