# Telehealth



## pdinapoli (Mar 15, 2020)

I work in a primary care physician office looking to limit patient interaction and primarily use phone or video capabilities.  These services are entirely new and never billed prior to the national emergency.  I have begun billing 99441-99443, 98966-98962 and G2012.  I am trying to gain clarity on Medicare emergency rules giving patients access to telehealth.  I am reading it as thought the physician can bill for telehealth if they use Facetime and has been treating patient for 3 years same condition?  Any additional information or clarification on this topic would be greatly appreciated.


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## mitchellde (Mar 15, 2020)

Just remember for the codes you are using these must be services initiated by the patient and not a scheduled encounter.  They are not telemedicine.  Telemedicine uses regular office visit codes with the 02 POS and must be interactive audio and visual medium.  The patient must be in a qualified originating site and not at home at least for Medicare, these can be prior scheduled encounters


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## pdinapoli (Mar 15, 2020)

Thank you, I am aware of the above.  I'm looking for interpretation on some of these restrictions being lifted because of the national emergency.  It is my understanding that the originating site restriction has been lifted and services can be rendered via video and audio in the patients home.  Any clue?


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## mitchellde (Mar 15, 2020)

No i did not read that in any of the notices.  What I saw was that they would consider paying for the telephone calls and the Skype calls made by the patients. Medicare typically does not reimburse those.  I have not read any notice that lifted the originating site description for telehealth.  Instead the notices I read only reinforced the telehealth definition vs the telephone calls and Skype calls definition, and indicated that in most Regions Medicare would reimburse for the phone and Skype calls as an interim measure but you are to check with your region first.


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## midnight1995 (Mar 16, 2020)

Regarding the Telemedicine - I reviewed this from White House if I reading htis correctly they are waving the originating site - “We are providing $2.2 billion in public health funding for prevention, preparedness and response, including nearly a billion dollars specifically to alleviate the immense financial strain on state, local, tribal and territorial hospitals and health systems.  To protect public health, the bill will allow Medicare providers to extend telemedicine services to seniors regardless of where they live, at an estimated cost of $500 million  - does any one have the same readying on this


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## mitchellde (Mar 16, 2020)

Right now for telehealth the patient must live in a qualifying rural location, this announcement is waiving that but it does not address the originating site for the service.  It does not say the patient can be at home at the time of the service.  I would be careful in interpreting this to mean you can bill telehealth for a patient that is at home at the time of service.  You can however use telephone and online digital evaluation and management codes


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## Arnkpc (Mar 16, 2020)

midnight1995 said:


> Regarding the Telemedicine - I reviewed this from White House if I reading htis correctly they are waving the originating site - “We are providing $2.2 billion in public health funding for prevention, preparedness and response, including nearly a billion dollars specifically to alleviate the immense financial strain on state, local, tribal and territorial hospitals and health systems.  To protect public health, the bill will allow Medicare providers to extend telemedicine services to seniors regardless of where they live, at an estimated cost of $500 million  - does any one have the same readying on this



Where is that information? Can you provide a link?


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## mmiele1979 (Mar 16, 2020)

Work in a pediatrician's office.   We are also doing the same - limiting face to face visits and trying to do these via phone.  Brand new place of work and they don't have any coding book on site.  We have received information from our local medicaid office that we are ok to bill 99441-99443 and 98966-98962 but are unsure if we need to attach a 95 modifier.  Also concerned about place of service as most of these people will be at home.  Please advise where I can go to get these questions answered.


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## mitchellde (Mar 16, 2020)

No modifier,, those are phone visit and online such as Skype they are not telehealth you are really going to need a code book to assist you.. I suggest getting one from a bookstore such as a Barnes and Noble


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## PedsBiller29 (Mar 17, 2020)

I'm also researching this and so far UHC updated their policy on this about 4 hours ago.. still a lot of uncertainty with other commercial payers.

https://www.uhcprovider.com/en/resource-library/news/provider-telehealth-policies.html


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## Stefanie (Mar 18, 2020)

mitchellde said:


> No i did not read that in any of the notices.  What I saw was that they would consider paying for the telephone calls and the Skype calls made by the patients. Medicare typically does not reimburse those.  I have not read any notice that lifted the originating site description for telehealth.  Instead the notices I read only reinforced the telehealth definition vs the telephone calls and Skype calls definition, and indicated that in most Regions Medicare would reimburse for the phone and Skype calls as an interim measure but you are to check with your region first.









						MEDICARE TELEMEDICINE HEALTH CARE PROVIDER FACT SHEET | CMS
					

Medicare coverage and payment of virtual services INTRODUCTION:




					www.cms.gov
				





From this link:


*EXPANSION OF TELEHEALTH WITH 1135 WAIVER: *Under this new waiver, Medicare can pay for office, hospital, and other visits furnished via telehealth across the country and including in patient’s places of residence starting March 6, 2020.

*While they must generally travel to or be located in certain types of originating sites such as a physician’s office, skilled nursing facility or hospital for the visit, effective for services starting March 6, 2020 and for the duration of the COVID-19 Public Health Emergency, Medicare will make payment for Medicare telehealth services furnished to beneficiaries in any healthcare facility and in their home.*


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## dmrbilling (Mar 18, 2020)

If a patient is limited and does not have a computer or smartphone to have a visual visit with the provider. Billing for a telephone visit instead of a telemedicine would be appropriate. Has anyone been paid by Medicare for telephone calls? Since the elderly are the ones that cannot make it out to the clinic, Medicare would be the most common payer we would bill telephone calls with. Any feedback?


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## lisaneese (Mar 18, 2020)

What place of service code is everyone using for telephone calls?   What about digital visits?


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## LorraineLane (Mar 18, 2020)

lisaneese said:


> What place of service code is everyone using for telephone calls?   What about digital visits?




Telehealth POS code 02 is what I think you would use


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## lisaneese (Mar 18, 2020)

LorraineLane said:


> Telehealth POS code 02 is what I think you would use


Thank you


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## vcar (Mar 18, 2020)

I work for a facility owned multi-specialty practice with multiple locations.  Normal office services are billed POS 11 under each individual location.  In order to use POS 02 would we need to do multiple builds in our practice management software to reflect each office location or can we have IT build 1 location for the services possibly using the facility address?  I think it would need to be each individual office.  But our IT team is overwhelmed so I though I'd ask.  
Thanks!


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## C.Campbell (Mar 19, 2020)

I work for a small ortho practice- My physicians are wanting to call the patients on the schedule to offer telemedicine vs. face to face.
  My understanding is telemedicine should be patient initiated. So basically the patient should be the one to call for an appt. we explain we aren't doing face to face but can provide telehealth calls. They can either agree or not agree correct? 

They physician stand point is how do they know we can do it if we don't call to offer, and feel this should be ok since CMS has relaxed the guidelines. 

Any clarification would be greatly appreciated so I can explain to my Drs. or at least be confident we are doing this the correct way. 

Thanks!


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## PedsBiller29 (Mar 19, 2020)

Does anyone have any insight with commercial payers regarding telephone calls only? The emergency policy updates from Aenta, Florida Blue, Cigna, Humana, and UHC are all Covid specific only addressing "virtual check-ins" of 5-10 mins as covered and copays wavied.. there is no clarity for normal telephone consults only, non related to CoVid. Should i bill for the normal telephone code set 99441-99443/98966-98968?


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## kstine713 (Mar 19, 2020)

Just in case anyone needed to see all the restrictions that have been lifted via by CMS regarding telehealth: 






						MEDICARE TELEMEDICINE HEALTH CARE PROVIDER FACT SHEET | CMS
					

Medicare coverage and payment of virtual services INTRODUCTION:




					www.cms.gov


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## oakesgirl@hotmail.com (Mar 20, 2020)

So for a visual visit with a patient in their home would you  bill the office visit (99212-99215) with POS (11) of POS (02)? And for a phone call, 99441-99443, is the POS (11)?


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## Ccdgea08 (Mar 20, 2020)

oakesgirl@hotmail.com said:


> So for a visual visit with a patient in their home would you  bill the office visit (99212-99215) with POS (11) of POS (02)? And for a phone call, 99441-99443, is the POS (11)?




POS 2 for telehealth GT modifier for medicare and 95 for commercial showing it was a telehealth visit.  you do not need the 99441 - 99443 codes.  the only insurance covering these is AETNA.


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## Ccdgea08 (Mar 20, 2020)

mitchellde said:


> Just remember for the codes you are using these must be services initiated by the patient and not a scheduled encounter.  They are not telemedicine.  Telemedicine uses regular office visit codes with the 02 POS and must be interactive audio and visual medium.  The patient must be in a qualified originating site and not at home at least for Medicare, these can be prior scheduled encounters



They have lifted the restrictions patient can be home.  You can not see the patient in the office 24 hours before or 7 days after the telehealth call or you can not bill telehealth.  Per medicare change you can bill for any diagnosis by telehealth due to the pandemic.


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## Ccdgea08 (Mar 20, 2020)

LorraineLane said:


> Telehealth POS code 02 is what I think you would use




POS is 02 for telehealth medicare wants a GT modifier and commercial wants 95 when billing em visits.


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## Ccdgea08 (Mar 20, 2020)

PedsBiller29 said:


> Does anyone have any insight with commercial payers regarding telephone calls only? The emergency policy updates from Aenta, Florida Blue, Cigna, Humana, and UHC are all Covid specific only addressing "virtual check-ins" of 5-10 mins as covered and copays wavied.. there is no clarity for normal telephone consults only, non related to CoVid. Should i bill for the normal telephone code set 99441-99443/98966-98968?




As far as I know Aetna is the only one that will cover the 99441-99443/98966-98968 codes.  They all want some sort of video capable phone.  UHC is following medicare guidelines where you use a smart phone or video capable phone for office visits and use regular em codes with pos 2 and GT modifier for medicare and 95 modifier for commercial.  virtual check ins I think need a photo or prerecorded video from the patient to qualify.


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## Ccdgea08 (Mar 20, 2020)

vcar said:


> I work for a facility owned multi-specialty practice with multiple locations.  Normal office services are billed POS 11 under each individual location.  In order to use POS 02 would we need to do multiple builds in our practice management software to reflect each office location or can we have IT build 1 location for the services possibly using the facility address?  I think it would need to be each individual office.  But our IT team is overwhelmed so I though I'd ask.
> Thanks!


you would build in POS 2 telehealth.  you do not need a specific facility attached to the POS


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## Ccdgea08 (Mar 20, 2020)

Stefanie said:


> MEDICARE TELEMEDICINE HEALTH CARE PROVIDER FACT SHEET | CMS
> 
> 
> Medicare coverage and payment of virtual services INTRODUCTION:
> ...





midnight1995 said:


> Regarding the Telemedicine - I reviewed this from White House if I reading htis correctly they are waving the originating site - “We are providing $2.2 billion in public health funding for prevention, preparedness and response, including nearly a billion dollars specifically to alleviate the immense financial strain on state, local, tribal and territorial hospitals and health systems.  To protect public health, the bill will allow Medicare providers to extend telemedicine services to seniors regardless of where they live, at an estimated cost of $500 million  - does any one have the same readying on this





pdinapoli said:


> I work in a primary care physician office looking to limit patient interaction and primarily use phone or video capabilities.  These services are entirely new and never billed prior to the national emergency.  I have begun billing 99441-99443, 98966-98962 and G2012.  I am trying to gain clarity on Medicare emergency rules giving patients access to telehealth.  I am reading it as thought the physician can bill for telehealth if they use Facetime and has been treating patient for 3 years same condition?  Any additional information or clarification on this topic would be greatly appreciated.




Medicare you must bill regular em codes 99201-99215 with GT modifier POS 2 telehealth.  united health is following medicare guidelines.  They can use a smart phone or computer and use any kind of video calling such as face time, skype, video calling.  The patient must be an established medicare patient or if seeing the same physician and just went from bcbs to medicare and has not seen the doctor since getting medicare.  Medicare will still pay.


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## Ccdgea08 (Mar 20, 2020)

midnight1995 said:


> Regarding the Telemedicine - I reviewed this from White House if I reading htis correctly they are waving the originating site - “We are providing $2.2 billion in public health funding for prevention, preparedness and response, including nearly a billion dollars specifically to alleviate the immense financial strain on state, local, tribal and territorial hospitals and health systems.  To protect public health, the bill will allow Medicare providers to extend telemedicine services to seniors regardless of where they live, at an estimated cost of $500 million  - does any one have the same readying on this




yes they have


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## janyhopkins (Mar 20, 2020)

Following


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## pattywhilhite@fmclp.com (Mar 20, 2020)

Does anyone know if INITIAL nursing home visits can be billed using telemedicine?  I am not really finding anything on it.   The list that CMS has as approved codes do not have them listed but that was updated in November and they are not on the list.  CPT codes 99304-99306.


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## lisaneese (Mar 20, 2020)

Is anyone billing regular phone visits if they cannot do "telehealth" with a smart phone or other capabilities.   I understand that they are not covered by Medicare but what options do we have when phone calls are the only way to communicate with the patient?   Also, what about phone calls that last longer than 30 minutes?


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## arochier (Mar 20, 2020)

The facility I work with is new at this with the national emergency. So I am just trying to make sure we do it correctly. So do we bill the Telemedicine codes if the patient initiates the call and the provider or nurse talks to them to determine if they really need to present or just treats them over the phone. Or should be billing the regular office visit codes with 95 modifier for commercial payers (that's really all we bill), and POS 02? Also looking for some insight on what the documentation should look like.
Thanks


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## SharonCollachi (Mar 21, 2020)

C.Campbell said:


> My understanding is telemedicine should be patient initiated. So basically the patient should be the one to call for an appt. we explain we aren't doing face to face but can provide telehealth calls. They can either agree or not agree correct?



To bill the telephone call codes, the patient must initiate the call.  Say they were seen 10 days ago and it's not getting better (whatever they were seen for).  Doc talks to them for 10 minutes, changes their med, says call me if anything changes.  THAT is the type of phone call that is 99441-99443.

The telehealth services that you are describing are entirely different, and are the ones billed with regular codes and POS 02, and do NOT have to be initiated by the patient.


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## Cynthia Hughes (Mar 22, 2020)

Medicare's fact sheet does a good job of comparing the different distant-site services: https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet
Don't miss out on code 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) for your Medicare patients who call in to speak with the doctor about minor concerns in lieu of a face-to-face visit. This service can be delivered by phone (no video component required), patient portal, email, etc. 

Also, bill telemedicine modifier 95 and place of service 02 only for audiovisual communications. If not familiar, the CPT description of modifier 95 is helpful.

For online digital services, advanced practice professionals (eg, NP, PA, CNS) bill the online digital services E/M codes. Other professionals, like nutritionists and therapists, bill the 989 codes in the medicine section or the Medicare G codes.

Even when the distant-site service is offered in lieu of a scheduled face-to-face appointment, be sure to document the patient's acknowledgement of financial responsibility and consent to the phone, email, or telehealth service. Patients will likely think anything other than a face-to-face visit in the office is free.

Hope that helps.
Cindy


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## elopezmanager (Mar 23, 2020)

The Texas Governor  released the following.  But I am still confused.  i am not sure is he is calling telephone only encounters Telemedicine and therefore billable as Telemedicine? if you keep reading, the article starts talking about making sure that the documentation fits the description of the CPT code, the method of delivery and if the insurance carrier needs a modifier to make sure we meet that guideline.  

So are telephone only evaluations billable with the an office visit code (99201-99215)? With modifiers 95 or GT?

Thank you for your time!!!!


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## mitchellde (Mar 23, 2020)

The GT modifer is not used for Medicare unless you are specifically designated to use the modifer and it is based on geograph.  They created the 02POS as a better way to designate telehealth from face to face.  Commercial payers use the 95.  You do not use the 02 POS for the phone call or e-visits because those codes already specify what they are used for.


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## twdevore (Mar 23, 2020)

Our facility is using 99211-99215 with a GT modifier and POS 02. I'm assuming that the document will still need to have the appropriate number of elements to support the level billed. Notes will still require appropriate number of ROS elements, MDM and documented time.  All the rules regarding these codes revolve around them being done face to face. I've been searching for something that explains documentation requirements when they are not done face to face and am coming up empty handed...Any have anything?


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## csperoni (Mar 23, 2020)

twdevore said:


> Our facility is using 99211-99215 with a GT modifier and POS 02. I'm assuming that the document will still need to have the appropriate number of elements to support the level billed. Notes will still require appropriate number of ROS elements, MDM and documented time.  All the rules regarding these codes revolve around them being done face to face. I've been searching for something that explains documentation requirements when they are not done face to face and am coming up empty handed...Any have anything?


Since Debra is probably tired of saying the same thing in multiple postings, I'll answer and summarize. Everything below is only for providers that may bill E/M services (physicians, nurse practitioners, physician assistants, etc.) 
1) Telehealth (which is interactive audio and video, not just telephone) is billed with E/M codes. POS 02. Commercial insurance modifier 95. Medicare no modifier UNLESS you are in a geographic area that was always allowed to bill telehealth, then GT as you would have prior.
Telehealth is typically only for established patients, but CMS has stated they will not look into whether or not you actually saw the patient prior - kind of an don't ask, don't tell policy.
It may be a scheduled visit. 
2) Documentation of history, exam & MDM should be done as usual, realizing that exam cannot really be performed. You MIGHT be able to get constitutional (general appearance/vitals) and/or psychiatric (mood, judgment, etc).  IF > 50% of visit is counseling, then you may bill based on time, just like for an in person office visit.  Again, if billing based on time, that must be documented as well. 

A TELEPHONE call is NOT TELEHEALTH.  Telephone call must be patient initiated (you may inform pt of the service, but you can't start cold calling your patients and then bill your discussion). Must be established patient. Not originating from a visit in previous 7 days, or resulting in an upcoming appointment at soonest available.  Not a scheduled visit.  POS 11.  Medicare use G2012.  Commercial use 99441-99443. 

There are also codes 99421-99423 for encounters taking place via your EMR's patient portal. We will not be using those, so I haven't really researched those.

UPDATE ON 04/02/2020 TO ORIGINAL POST, AS GUIDANCE FROM CMS HAS CHANGED
As of 03/31/2020, CMS states for telehealth, "report the POS code that would have been reported had the service been furnished in person." with modifier -95 to designate it was telehealth.  This way, you will get full reimbursement for nonfacility location, instead of reduced facility rate with POS 02.
Medicare will also now reimburse 99441-99443.  

Guidance about POS/modifiers page 14-15.  Guidance about 99441-99443 starts at bottom of 126.
This is CMS guidance only, and you should check with your commercial carriers about their rules.  

For both telehealth and telephone encounters, you should inform the patient that the discussion is a billable encounter & document their verbal consent in the note.  For telehealth you should document the location of the patient, and the location of the provider and of course something noting that the visit took place via interactive audio and video.  For telephone, I do not recall seeing any requirement to document patient or provider location, but it certainly can't hurt in case I missed it.     

While CMS has specifically stated they will cover these expanded services during the emergency, there is no such guarantee from commercial carriers.  Many major carriers have come out with a policy that telehealth and telephone encounters will be covered, but this is not universal.


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## Shuggins1 (Mar 24, 2020)

pattywhilhite@fmclp.com said:


> Does anyone know if INITIAL nursing home visits can be billed using telemedicine?  I am not really finding anything on it.   The list that CMS has as approved codes do not have them listed but that was updated in November and they are not on the list.  CPT codes 99304-99306.


Did anyone every answer this. I am looking for the same information. We were going to go with the regular code and add the 02 POS. We still are not positive


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## Cynthia Hughes (Mar 24, 2020)

Shuggins1 said:


> Did anyone every answer this. I am looking for the same information. We were going to go with the regular code and add the 02 POS. We still are not positive


The current list of services that are covered by Medicare when provided via telehealth is found here - https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.


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## lennysara (Mar 24, 2020)

csperoni said:


> Since Debra is probably tired of saying the same thing in multiple postings, I'll answer and summarize. Everything below is only for providers that may bill E/M services (physicians, nurse practitioners, physician assistants, etc.)
> 1) Telehealth (which is interactive audio and video, not just telephone) is billed with E/M codes. POS 02. Commercial insurance modifier 95. Medicare no modifier UNLESS you are in a geographic area that was always allowed to bill telehealth, then GT as you would have prior.
> Telehealth is typically only for established patients, but CMS has stated they will not look into whether or not you actually saw the patient prior - kind of an don't ask, don't tell policy.
> It may be a scheduled visit.
> ...


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## LAKEENYA (Mar 25, 2020)

csperoni said:


> Since Debra is probably tired of saying the same thing in multiple postings, I'll answer and summarize. Everything below is only for providers that may bill E/M services (physicians, nurse practitioners, physician assistants, etc.)
> 1) Telehealth (which is interactive audio and video, not just telephone) is billed with E/M codes. POS 02. Commercial insurance modifier 95. Medicare no modifier UNLESS you are in a geographic area that was always allowed to bill telehealth, then GT as you would have prior.
> Telehealth is typically only for established patients, but CMS has stated they will not look into whether or not you actually saw the patient prior - kind of an don't ask, don't tell policy.
> It may be a scheduled visit.
> ...



CSperoni, thank you for the detailed explanation. Maybe you can answer another question. How do you handle the coding when the provider starts the encounter with the patient via telemedicine and due to some technical issues they are unable to complete it and finish the encounter via telephone only?


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## rlmiller (Mar 25, 2020)

Can a provider be at home and code and bill telehealth visits with remote access to the patients chart?  I cannot find anything that states the provider MUST be in their office to bill telehealth visits under the 1135 Waiver.


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## csperoni (Mar 26, 2020)

LAKEENYA said:


> CSperoni, thank you for the detailed explanation. Maybe you can answer another question. How do you handle the coding when the provider starts the encounter with the patient via telemedicine and due to some technical issues they are unable to complete it and finish the encounter via telephone only?


Someone else asked this in a different thread.  I offered my unofficial opinion of billing telehealth if most of the encounter took place via video and telephone encounter if it didn't work at all, or minimally.  I would rather err on the side of caution in this unusual circumstance.


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## csperoni (Mar 26, 2020)

rlmiller said:


> Can a provider be at home and code and bill telehealth visits with remote access to the patients chart?  I cannot find anything that states the provider MUST be in their office to bill telehealth visits under the 1135 Waiver.


I don't know if this is addressed in any of the official CMS guidance, but this exact question was posed during NGS Medicare telehealth webinar yesterday afternoon.  The provider may be at home, or another location.  Still bill POS 02.

*UPDATE ON 04/02/2020 TO ORIGINAL POST, AS GUIDANCE FROM CMS HAS CHANGED*
As of 03/31/2020, CMS states for telehealth, "report the POS code that would have been reported had the service been furnished in person." with modifier -95 to designate it was telehealth.  This way, you will get full reimbursement for nonfacility location, instead of reduced facility rate with POS 02.
Medicare will also now reimburse 99441-99443.  

Guidance about POS/modifiers page 14-15.  Guidance about 99441-99443 starts at bottom of 126.
This is CMS guidance only, and you should check with your commercial carriers about their rules.


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## KaylaRieken (Mar 26, 2020)

Does a visual physical exam count? My provider asked this.


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## csperoni (Mar 27, 2020)

KaylaRieken said:


> Does a visual physical exam count? My provider asked this.


MOST of the organ systems cannot just be examined visually.  You could maybe get constitutional, psych, possibly limited skin.  Via video only, you cannot examine eyes, ENT, respiratory, cardiovascular, GI, GU, lymphatic, musculoskeletal or neurologic.  To the limited extent that an exam via video only is possible, you can count those if the documentation meets the requirements of 1995 or 1997.  
In our practice, I have advised the providers that we will code based on time since basically 100% of time is counseling.


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## trarut (Mar 27, 2020)

csperoni said:


> ::snipped::  For telehealth you should document the location of the patient, and the location of the provider and of course something noting that the visit took place via interactive audio and video.  For telephone, I do not recall seeing any requirement to document patient or provider location, but it certainly can't hurt in case I missed it. ::snipped::



Will you provide further insight into what you are documenting for location?


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## lljjs2000@yahoo.com (Mar 27, 2020)

I am fairly new to coding. I work for group of physicians and telehealth is new for us. 

If the patient is coming to the parking lot of the doctors office, a staff member goes out and checks their temp, has the patient to call the office and the call is transferred to the nurse to triage and the call is transferred to the physician and he/she completes the exam. Is this considered telehealth or are these consider a phone call? The doctor never has a visual of the patient.


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## Kristen Bensel (Mar 27, 2020)

I found this today on the AMA website.
https://www.ama-assn.org/practice-management/digital/ama-quick-guide-telemedicine-practice

 It looks like the restriction that telephone encounters are not able to be billed as E/M has been lifted temporarily-which is amazing. (I found that information first on the United Healthcare website from the UHC link at the bottom of this page.)  But I found this particular link very helpful with the visual aids!

https://www.ama-assn.org/system/files/2020-03/covid-19-coding-advice.pdf 

Hope this is helpful for everyone.


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## vgodoy (Mar 27, 2020)

We are doing telehealth visit but the providers want to start doing new patients appointments. Can the Medical Assistants call the patient collect the CC and social and medication history before the Provider starts the Audio / Video telehalth visit? I cant find documentation saying no but MA's in California are not permitted to do Assesments.


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## SharonCollachi (Mar 27, 2020)

pdinapoli said:


> I am reading it as thought the physician can bill for telehealth if they ... has been treating patient for 3 years same condition?



Not 3 years same condition, just established patient (under the old rules - the emergency rules seem to change by the hour).


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## lmorris319 (Mar 28, 2020)

Ccdgea08 said:


> As far as I know Aetna is the only one that will cover the 99441-99443/98966-98968 codes.  They all want some sort of video capable phone.  UHC is following medicare guidelines where you use a smart phone or video capable phone for office visits and use regular em codes with pos 2 and GT modifier for medicare and 95 modifier for commercial.  virtual check ins I think need a photo or prerecorded video from the patient to qualify.


UHC does not want any modifier and neither does medicare.  Regular e/m codes with 02 place of service. Horizon, Aetna, AmeriHealth all want GT or 95 modifiers along with place of service 02.


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## trarut (Mar 28, 2020)

I read somewhere - and am trying to find the reference again - that the physician needs to review history, medication reconciliation, etc. while on the video portion of the call with the patient.  Has anyone else seen this?


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## harpermmb (Mar 29, 2020)

Kristen Bensel said:


> I found this today on the AMA website.
> https://www.ama-assn.org/practice-management/digital/ama-quick-guide-telemedicine-practice
> 
> It looks like the restriction that telephone encounters are not able to be billed as E/M has been lifted temporarily-which is amazing. (I found that information first on the United Healthcare website from the UHC link at the bottom of this page.)  But I found this particular link very helpful with the visual aids!
> ...


Thank you


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## csperoni (Mar 29, 2020)

Kristen Bensel said:


> I found this today on the AMA website.
> https://www.ama-assn.org/practice-management/digital/ama-quick-guide-telemedicine-practice
> 
> It looks like the restriction that telephone encounters are not able to be billed as E/M has been lifted temporarily-which is amazing. (I found that information first on the United Healthcare website from the UHC link at the bottom of this page.)  But I found this particular link very helpful with the visual aids!
> ...


The AMA coding advice seems to state audio/video or audio only.  I will note that it is a little confusing as 99441-99443 are also listed in another column.  And there's a statement of "(Flexibility: Permit audio only for E/M telehealth)."  Flexibility by who?? 
The CMS advice clearly states otherwise. I have not seen any commercial insurance guidance that permits E/M when telephone only (I have seen policies stating telephone to be billed with G2012 or 99441-99443, depending on carrier). In our practice, we will only be billing telehealth for audio and video unless CMS provides other guidance.  
https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf     See Question 8.  Specifies AUDIO/VIDEO.


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## csperoni (Mar 29, 2020)

trarut said:


> Will you provide further insight into what you are documenting for location?


We are documenting something along the lines of:
Services provided via telehealth (Skype) after written consent from the patient on DATE at TIME via non HIPAA platform.  Patient was located at residence. Provider was located in (town) office.
or 
Services provided via telehealth (Skype) after verbal consent from the patient on DATE at TIME by EMPLOYEE via non HIPAA platform. Patient was located at daughter's residence in (town, state). Provider was located in his own residence.
I have not seen any requirement for the exact location.  NGS Medicare had a webinar this past Wednesday and the question was posed about provider's location.  It was stated the provider may be at his own home, and did not need to specify the address of his personal residence.  Somewhere along the road, I heard that if the patient is NOT in the same state where your office is, you should specify that.  Typically, you cannot provide services to a patient located in a state where physician is not licensed, but it was permitted during the emergency.


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## trarut (Mar 30, 2020)

Thank you, csperoni!  I truly appreciate how much information you have provided regarding telehealth across the forum


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## lpool (Mar 30, 2020)

csperoni said:


> MOST of the organ systems cannot just be examined visually.  You could maybe get constitutional, psych, possibly limited skin.  Via video only, you cannot examine eyes, ENT, respiratory, cardiovascular, GI, GU, lymphatic, musculoskeletal or neurologic.  To the limited extent that an exam via video only is possible, you can count those if the documentation meets the requirements of 1995 or 1997.
> In our practice, I have advised the providers that we will code based on time since basically 100% of time is counseling.


If coding based on time, I was reading that I can bill 99213 based on 15 minutes.  Is that correct?  Thanks!


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## JulieP (Mar 30, 2020)

csperoni said:


> I don't know if this is addressed in any of the official CMS guidance, but this exact question was posed during NGS Medicare telehealth webinar yesterday afternoon.  The provider may be at home, or another location.  Still bill POS 02.


If the provider is at home during the phone call/telehealth visit with patient, what do we use for Appointment Facility on our claims? This is not the same as POS. If we have multiple office locations do I just pick one at random to use for Appointment Facility?


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## trarut (Mar 30, 2020)

lpool - we have 99213 with a range of 15-20 minutes when coding based on time.


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## csperoni (Mar 31, 2020)

JulieP said:


> If the provider is at home during the phone call/telehealth visit with patient, what do we use for Appointment Facility on our claims? This is not the same as POS. If we have multiple office locations do I just pick one at random to use for Appointment Facility?


NGS Medicare (webinar 3/25/20) did offer the guidance of putting the office location on the claim, and the provider may be at home.  If you have multiple locations, I would either choose the office location the provider is typically at, or the main office location if there is one.  That specific question was not posed and I have not seen official guidance regarding multiple locations, but I can't imagine it matters much unless your locations are in different Medicare jurisdictions.


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## janellefinnie@sbcglobal.net (Apr 1, 2020)

csperoni said:


> Since Debra is probably tired of saying the same thing in multiple postings, I'll answer and summarize. Everything below is only for providers that may bill E/M services (physicians, nurse practitioners, physician assistants, etc.)
> 1) Telehealth (which is interactive audio and video, not just telephone) is billed with E/M codes. POS 02. Commercial insurance modifier 95. Medicare no modifier UNLESS you are in a geographic area that was always allowed to bill telehealth, then GT as you would have prior.
> Telehealth is typically only for established patients, but CMS has stated they will not look into whether or not you actually saw the patient prior - kind of an don't ask, don't tell policy.
> It may be a scheduled visit.
> ...




What happens for appointments (usually routine followups, med checks etc) that are scheduled and the patient does not have video capabilities, so provider completes the visit over the phone only?  What codes are used for those situations?  They are happening.  Do we just use the regular E/M code and modify?


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## AKBuckley (Apr 1, 2020)

Given that Medicare is now covering (as of 3/30/20) Telephone Visits 99421-23.  Seeing guidance to use POS 11 if initiated from clinic.  If using POS 11, would you append the modifier 95 to the 99421-23?


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## dsolak1965 (Apr 1, 2020)

Shuggins1 said:


> Did anyone every answer this. I am looking for the same information. We were going to go with the regular code and add the 02 POS. We still are not positive





pattywhilhite@fmclp.com said:


> Does anyone know if INITIAL nursing home visits can be billed using telemedicine?  I am not really finding anything on it.   The list that CMS has as approved codes do not have them listed but that was updated in November and they are not on the list.  CPT codes 99304-99306.




Attached is the updated list of approved Medicare Telehealth services from the CMS wesite as of 4/1/2020


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## dsolak1965 (Apr 1, 2020)

In regards to POS 02 or 11 for other than phone encounters:

Final ruling (as of 4/1/2020) per the Federal Register from the Department of Health and Human Services: Section II

A. Payment for Medicare Telehealth Services Under Section 1834(m) of the Act


To implement this change on an interim basis, we are instructing physicians and
practitioners who bill for Medicare telehealth services to report the POS code that would have
been reported had the service been furnished in person. This will allow our systems to make
appropriate payment for services furnished via Medicare telehealth which, if not for the PHE for
the COVID-19 pandemic, would have been furnished in person, at the same rate they would have
been paid if the services were furnished in person. Given the potential importance of using
telehealth services as means of minimizing exposure risks for patients, practitioners, and the
community at large, we believe this interim change will maintain overall relativity under the PFS
for similar services and eliminate potential financial deterrents to the clinically appropriate use of
telehealth. Because we currently use the POS code on the claim to identify Medicare telehealth
services, we are finalizing on an interim basis the use of the CPT telehealth modifier, modifier
95, which should be applied to claim lines that describe services furnished via telehealth. We
note that we are maintaining the facility payment rate for services billed using the general 
telehealth POS code 02, should practitioners choose, for whatever reason, to maintain their
current billing practices for Medicare telehealth during the PHE for the COVID-19 pandemic.


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## kstine713 (Apr 1, 2020)

I wanted to make sure everyone saw the update from CMS yesterday: Offices should bill place of service as if visit was performed face to face (not 02) if they want to receive non-facility reimbursement, and they should use modifier 95.



			https://codingintel.com/telemedicine-and-covid-19-faq/
		



			https://codingintel.com/wp-content/uploads/2020/04/CodingandReimbursementduringtheCOVID19PandemicPACApril12020.pdf
		


Please also find attached CMS update and reference pages 14-15


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## dsolak1965 (Apr 2, 2020)

AKBuckley said:


> Given that Medicare is now covering (as of 3/30/20) Telephone Visits 99421-23.  Seeing guidance to use POS 11 if initiated from clinic.  If using POS 11, would you append the modifier 95 to the 99421-23?


Telephone visit codes are 99441-99443
E-visits are 99421-99423
From all the articles I have reviewed thus far (and there are many) no modifiers are required for either of these methods as they are 'non face to face' encounters (with that being said, you may want to check with your local carriers as rules are changing every day)


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## Reqz0167 (Apr 6, 2020)

I saw a video from the American Academy of Pediatrics and they are stating that if a telemedicine video/audio visit turns into a curbside for a "swab" then we can code both services on the same claim but use two different place of service codes: example: 99213, 25,95 with pos 2 and 87804 pos 11....has anyone ever done this? I can't find anything with this type of scenario...
Coding During the COVID-19 Pandemic
http://send.mm.aap.org/link.cfm?r=i...Sri0Ld8waYq5WSLw~~&t=AsFn6srIn8MQx7bt8GGzDg~~


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## lcohen4 (Apr 7, 2020)

does anyone have suggestion for a physician that does not have an "office" location where patients are usually seen, now has an RN going to patient home to take COVID-19 swab and set-up the telehealth visit with provider. Since CMS says to bill POS and codes as you normally would, just add modifier 95, i recommended that Home Visit CPT codes 99341-99350 should be billed since under normal circumstances that is what the provider would have billed. 

and if this is correct, does anyone have clarification from CMS you can find that allows the home visit to also be coded based on time? all of the CMS releases regarding coding E/M based on time only refer to office visits cpt codes 99205-99215


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## reed.rach@yahoo.com (Apr 7, 2020)

lmorris319 said:


> UHC does not want any modifier and neither does medicare.  Regular e/m codes with 02 place of service. Horizon, Aetna, AmeriHealth all want GT or 95 modifiers along with place of service 02.


*Billing for Professional Telehealth Services During the Public Health Emergency*
Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries, CMS will now allow for more than 80 additional services to be furnished via telehealth. When billing professional claims for non-traditional telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE), bill with the Place of Service (POS) equal to what it would have been in the absence of a PHE, along with a modifier 95, indicating that the service rendered was actually performed via telehealth. As a reminder, CMS is not requiring the “CR” modifier on telehealth services. However, consistent with current rules for traditional telehealth services, there are two scenarios where modifiers are required on Medicare telehealth professional claims:

Furnished as part of a federal telemedicine demonstration project in Alaska and Hawaii using asynchronous (store and forward) technology, use GQ modifier
Furnished for diagnosis and treatment of an acute stroke, use G0 modifier
 Traditional Medicare telehealth services professional claims should reflect the designated POS code 02-Telehealth, to indicate the billed service was furnished as a professional telehealth service from a distant site. There is no change to the facility/non-facility payment differential applied based on POS. Claims submitted with POS code 02 will continue to pay at the facility rate


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## reed.rach@yahoo.com (Apr 7, 2020)

https://www.cms.gov/about-cms/emergency-preparedness-response-operations/current-emergencies/coronavirus-waivers

*Billing for Professional Telehealth Services During the Public Health Emergency*
Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries, CMS will now allow for more than 80 additional services to be furnished via telehealth. When billing professional claims for non-traditional telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE), bill with the Place of Service (POS) equal to what it would have been in the absence of a PHE, along with a modifier 95, indicating that the service rendered was actually performed via telehealth. As a reminder, CMS is not requiring the “CR” modifier on telehealth services. However, consistent with current rules for traditional telehealth services, there are two scenarios where modifiers are required on Medicare telehealth professional claims:

Furnished as part of a federal telemedicine demonstration project in Alaska and Hawaii using asynchronous (store and forward) technology, use GQ modifier
Furnished for diagnosis and treatment of an acute stroke, use G0 modifier
 Traditional Medicare telehealth services professional claims should reflect the designated POS code 02-Telehealth, to indicate the billed service was furnished as a professional telehealth service from a distant site. There is no change to the facility/non-facility payment differential applied based on POS. Claims submitted with POS code 02 will continue to pay at the facility rate


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## lcohen4 (Apr 7, 2020)

yes, i have that information.. thank you.


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## reed.rach@yahoo.com (Apr 7, 2020)

reed.rach@yahoo.com said:


> https://www.cms.gov/about-cms/emergency-preparedness-response-operations/current-emergencies/coronavirus-waivers
> 
> *Billing for Professional Telehealth Services During the Public Health Emergency*
> Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries, CMS will now allow for more than 80 additional services to be furnished via telehealth. When billing professional claims for non-traditional telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE), bill with the Place of Service (POS) equal to what it would have been in the absence of a PHE, along with a modifier 95, indicating that the service rendered was actually performed via telehealth. As a reminder, CMS is not requiring the “CR” modifier on telehealth services. However, consistent with current rules for traditional telehealth services, there are two scenarios where modifiers are required on Medicare telehealth professional claims:
> ...



*Further Promote Telehealth in Medicare*

Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries, CMS will now allow for more than 80 additional services to be furnished via telehealth. During the public health emergencies, individuals can use interactive apps with audio and video capabilities to visit with their clinician for an even broader range of services. Providers also can evaluate beneficiaries who have audio phones only.
In addition, CMS is allowing physicians to supervise their clinical staff using virtual technologies when appropriate, instead of requiring in-person presence


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## lcohen4 (Apr 7, 2020)

Thank you.. have you read the just released MLN matter update regarding modifier CS?  Are you interpreting that any visits related to the testing of COVID-19 do not get the modifier?  

*Families First Coronavirus Response Act Waives Coinsurance and Deductibles for Additional COVID-19 Related Services*
The Families First Coronavirus Response Act waives cost-sharing under Medicare Part B (coinsurance and deductible amounts) for Medicare patients for COVID-19 testing-related services. These services are medical visits for the HCPCS evaluation and management categories described below when an outpatient provider, physician, or other providers and suppliers that bill Medicare for Part B services orders or administers COVID-19 lab test U0001, U0002, or 87635.
Cost-sharing *does not* apply for COVID-19 testing-related services, which are medical visits that: are furnished between March 18, 2020 and the end of the Public Health Emergency (PHE); that result in an order for or administration of a COVID-19 test; are related to furnishing or administering such a test or to the evaluation of an individual for purposes of determining the need for such a test; and are in any of the following categories of HCPCS evaluation and management codes:

Office and other outpatient services
Hospital observation services
Emergency department services
Nursing facility services
Domiciliary, rest home, or custodial care services
Home services
Online digital evaluation and management services
Cost-sharing does not apply to the above medical visit services for which payment is made to: 

Hospital Outpatient Departments paid under the Outpatient Prospective Payment System
Physicians and other professionals under the Physician Fee Schedule
Critical Access Hospitals (CAHs)
Rural Health Clinics (RHCs)
Federally Qualified Health Centers (FQHCs)
*For services furnished on March 18, 2020, and through the end of the PHE, outpatient providers, physicians, and other providers and suppliers that bill Medicare for Part B services under these payment systems should use the CS modifier on applicable claim lines to identify the service as subject to the cost-sharing wavier for COVID-19 testing-related services and should NOT charge Medicare patients any co-insurance and/or deductible amounts for those services.  ????*
For professional claims, physicians and practitioners who did not initially submit claims with the CS modifier must notify their Medicare Administrative Contractor (MAC) and request to resubmit applicable claims with dates of service on or after 3/18/2020 with the CS modifier to get 100% payment.


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## hofm04 (Apr 7, 2020)

pdinapoli said:


> I work in a primary care physician office looking to limit patient interaction and primarily use phone or video capabilities.  These services are entirely new and never billed prior to the national emergency.  I have begun billing 99441-99443, 98966-98962 and G2012.  I am trying to gain clarity on Medicare emergency rules giving patients access to telehealth.  I am reading it as thought the physician can bill for telehealth if they use Facetime and has been treating patient for 3 years same condition?  Any additional information or clarification on this topic would be greatly appreciated.



here are a few sources
see federalregister.gov/d/2020-06990   
telephone is under section S   





 this one defines telephone separately from telehealth

also see donself website  he has a free webinar and pdf.


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## lcohen4 (Apr 7, 2020)

this is a good source of information: https://www.acponline.org/practice-...telehealth-coding-and-billing-during-covid-19


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## valholsinger (Apr 7, 2020)

Our providers/doctors are now providing after hours telephone services.  Is there a code that can be used along with 99441-99443 to denote after hours?


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## trugriff (Apr 8, 2020)

What about a telehealth visit performed but the peds provider wants the patient to come to the office for a throat swab or u/a? If billing a telehealth visit can you add the strep test or u/a to billing when billing POS 02?


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## cappy (Apr 9, 2020)

valholsinger said:


> Our providers/doctors are now providing after hours telephone services.  Is there a code that can be used along with 99441-99443 to denote after hours?


99050 = Services provided in the office at times other than regularly scheduled office hours, or days when the office is normally closed (eg, holidays, Saturday or Sunday), in addition to basic service 
99051 =  Service(s) provided in the office during regularly scheduled evening, weekend, or holiday office hours, in addition to basic service

Our main payer is BCBS NC and they informed me we can still bill these codes with telehealth, BUT, I have not gotten any of the claims back yet to see if they are actually paying.


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## sjomurphy88 (Apr 9, 2020)

Has anyone run into a patient being involved in a car accident and then seeing the provider via telehealth? I am a coder for primary care centers and this happened this morning. I cannot find anything on it.


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## paintgirl (Apr 9, 2020)

I have a question about the CR modifier. I work in a peds clinic in Oregon and we just started doing telehealth visits. We were just told we need to be appending that mod to our telehealth visits. I think this is HCPCS mod for Medicare only. We do not have any Medicare pt's just commercial and medicaid. Thoughts?


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## SienTC1720 (Apr 10, 2020)

We have a situation we aren't really clear on how to code, for a dermatology practice, the provider has asked:

Any idea of how I should bill the following? 
I do an evaluation over the phone, then have the patient e-mail me photos that I review and develop an assessment, and then call back and discuss a plan (and call in prescription(s) if needed.

Obviously it depends quite a bit on the payer, but we are generally thinking E/M codes would be the best fit for these, and going by time spent.


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## csperoni (Apr 10, 2020)

Was any of the "phone" actually done with video?  If so, then E/M are definitely appropriate.  If it was telephone only, it seems E/M is not appropriate, unless the specific carrier has instructed audio only is billed with E/M.  
If audio only with CMS guidelines, it seems it would be 99441-99443 for telephone, and perhaps G2010 for the "store and forward" reviewing of photos?  I do not know the current rules and guidance on billing those together as we never have used G2010 and are not considering it.  
Anyone else should feel free to jump in & correct me on this one.


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## SienTC1720 (Apr 10, 2020)

csperoni said:


> Was any of the "phone" actually done with video?  If so, then E/M are definitely appropriate.  If it was telephone only, it seems E/M is not appropriate, unless the specific carrier has instructed audio only is billed with E/M.
> If audio only with CMS guidelines, it seems it would be 99441-99443 for telephone, and perhaps G2010 for the "store and forward" reviewing of photos?  I do not know the current rules and guidance on billing those together as we never have used G2010 and are not considering it.
> Anyone else should feel free to jump in & correct me on this one.



There was no video involved for these encounters, but wouldn't G2010 be bundled with the 9944X codes?

99441: Telephone E/M service provided by a physician 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 hrs or soonest available appointment

We are thinking this most accurately describes what we are doing.


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## csperoni (Apr 10, 2020)

Right, audio only is 99441-99443; audio with video is E/M.  The E/M codes are valued more than the audio only 99441-99443, but if you didn't have video, you can't bill 99441-99443 UNLESS the private carrier (not CMS) advised you may use E/M for audio only.  I think United HC is the only one I have heard allowing this.


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## tonyabcarr (Apr 10, 2020)

Is there a limit to the number of telephone encounters or telehealth visits during a time frame, as long as they are not related to a previous visit within the last 7 days or end in a decision for a face-to-face visit in the next 7 days?


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## SienTC1720 (Apr 10, 2020)

On the idea of a related service, what about patients who have ongoing problems, such as arthritis, and these are previous scheduled follow up visits now being performed by phone? It seems like anything other than emergent circumstances aren't even being considered in all the carriers instructions


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## Kristen Bensel (Apr 10, 2020)

csperoni said:


> The AMA coding advice seems to state audio/video or audio only.  I will note that it is a little confusing as 99441-99443 are also listed in another column.  And there's a statement of "(Flexibility: Permit audio only for E/M telehealth)."  Flexibility by who??
> The CMS advice clearly states otherwise. I have not seen any commercial insurance guidance that permits E/M when telephone only (I have seen policies stating telephone to be billed with G2012 or 99441-99443, depending on carrier). In our practice, we will only be billing telehealth for audio and video unless CMS provides other guidance.
> https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf     See Question 8.  Specifies AUDIO/VIDEO.


I have found some guidance from private payers, but I had to do alot of digging to find the information at first. Once I found the links though it was easy to go back and reference for updates that seem to happen alot for some of the payers. 

This is all as clear as mud at midnight!


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## oskolkoff (Apr 10, 2020)

What are the guidelines for documentations on a telephone visit? I've been sifting through a lot of the data.
Thanks for the help, Jennifer


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## tonyabcarr (Apr 17, 2020)

What if provider completes a telehealth visit and decides a true face-to-face exam is necessary?  Can you bill the telehealth and regular office visit both on same date of service, by the same provider?


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## csperoni (Apr 17, 2020)

tonyabcarr said:


> What if provider completes a telehealth visit and decides a true face-to-face exam is necessary?  Can you bill the telehealth and regular office visit both on same date of service, by the same provider?


The telehealth services should bundle into the face-to-face E/M.  You can combine the documentation and bill a higher level if appropriate.


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## tonyabcarr (Apr 20, 2020)

csperoni said:


> The telehealth services should bundle into the face-to-face E/M.  You can combine the documentation and bill a higher level if appropriate.


Thank you, Christine!  I haven't seen any guidelines for the telehealth visits (99202-99215) like there are for the telephone enounters (99441-99443) bundling the telephone encounter if seen 7 days prior, 24 hours after or at next urgent appointment.  Have I just missed those?


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## csperoni (Apr 20, 2020)

I'm not considering any new rules.  I'm just considering the pre-Covid guidelines for billing 2 visits in the same day.  Medicare generally does not permit 2 E/M same day.  There are exceptions for unrelated problems which could not have been addressed at the same time.
Medicare claims processing manual section 30.6.7.B 
*B. Office/Outpatient E/M Visits Provided on Same Day for Unrelated Problems*
As for all other E/M services except where specifically noted, the Medicare Administrative Contractors (MACs) may not pay two E/M office visits billed by a physician (or physician of the same specialty from the same group practice) for the same beneficiary on the same day unless the physician documents that the visits were for unrelated problems in the office, off campus-outpatient hospital, or on campus-outpatient hospital setting which could not be provided during the same encounter (e.g., office visit for blood pressure medication evaluation, followed five hours later by a visit for evaluation of leg pain following an accident).


			https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/clm104c12.pdf


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## RDickerhoof (May 27, 2020)

New question on telephone only codes. Here's the scenario, patient comes in for in office visit, Dr. orders CT scan, within 7 days of office visit, patient has telephone only visit with Dr. to go over CT scan results. Normally would bill 99441-3 but because within 7 days of original in office visit can't use these codes. How do I code the telephone only visit?


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## mmiele1979 (May 27, 2020)

You can’t bill for this.  It’s considered to be included in the original E/M.  There’s no other way to code it.  


RDickerhoof said:


> New question on telephone only codes. Here's the scenario, patient comes in for in office visit, Dr. orders CT scan, within 7 days of office visit, patient has telephone only visit with Dr. to go over CT scan results. Normally would bill 99441-3 but because within 7 days of original in office visit can't use these codes. How do I code the telephone only visit?


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## mmiele1979 (May 27, 2020)

mmiele1979 said:


> You can’t bill for this.  It’s considered to be included in the original E/M.  There’s no other way to code it.  IF you can justify another E/M visit with documentation from the call, (if normally the patient would have come in to discuss results and you would have billed it that way) THEN you can bill another separate E/M with POS 02 and whatever modifier the patient’s plan wants for telephone.


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