Anesthesia Coding Alert

Brush up on changes to guidelines, waivers.

Telehealth is playing an ever-important role in patient care due to the current COVID-19 public health emergency (PHE). And while anesthesia providers don’t normally deal with telehealth situations, many are now as they help fellow providers however they can.

Keep these latest updates in mind, knowing that they will remain in effect for the duration of the COVID-19 PHE.

Here are the highlights of that rule to help you stay connected to your patients in the weeks and months to come.

Place of Service Flexibilities

Telehealth services may now be furnished to patients “wherever they are located, including in the patient’s home,” CMS says in an interim final rule issued on March 30. Practitioners should also “report the POS code that would have been reported had the service been furnished in person,” according to the interim final rule.

Explanation: “This means, for example, using POS modifier 11 [Office] instead of 02 [Telehealth] to describe the point of service if the visit would normally have been conducted in the physician’s office,” Donelle Holle, RN, a healthcare, coding, and reimbursement consultant in Fort Wayne, Indiana, suggests.

Some codes that became effective March 1, 2020, and that might come into play during these situations include:

• 99217 (Observation care discharge day management …)
• 99327-99337 (Domiciliary or rest home visit …)
• 99341-99350 (Home visit for the evaluation and management of a new/ established patient …)
• 99477-99480 (Initial hospital care/Subsequent intensive care …)

Go to www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes for the updated list.

Technology: CMS’ definition of “interactive telecommunications system” will now include “two-way, real-time interactive communication between the patient and distant site physician or practitioner.” In other words, mobile phones may now be used for codes on the Medicare Telehealth Code list providing the communication is both aural and visual. For voice communications only with a physician or other qualified healthcare professional, you should still use 99441-99443 (Telephone evaluation and management service…) or G2012 (Brief communication technology-based service, e.g. virtual check-in …).

HIPAA Requirement Waivers

During this time, the Department of Health and Human Services’ Office of Civil Rights (HHS OIG) is waiving the Health Insurance Portability and Accountability Act (HIPPA) requirements that communications be encrypted. Providers may now use “everyday communications technologies, such as FaceTime or Skype … during the PHE.”

New patient exceptions: G2010 (Remote evaluation of recorded video and/or images …) and G2012 services can be furnished to both new and established patients. Additionally, for 99421-99423 and G2061-G2063 (Qualified nonphysician healthcare professional online assessment and management …), CMS will “relax enforcement … [and] not conduct review to consider whether those services were furnished to established patients.”

Office/outpatient E/M level selection: Per the interim final rule, during the PHE, you may report 99201-99215 (Office or other outpatient visit for the evaluation and management of a new/established patient …) in one of two ways when provided as a telemedicine service:

1) Using medical decision making (MDM) alone. This policy is “similar to the policy that will apply to all office/outpatient E/Ms beginning in 2021 under policies finalized in the CY 2020 PFS final rule,” according to the interim final rule, though you must use the 2020 definition of MDM.

2) Using “all of the time associated with the E/M on the day of the encounter,” regardless of the current guideline to only use time “when counseling and/or coordination of care dominates (more than 50 per cent) the encounter.” However, you must use the “typical times” listed in the current 2020 CPT^® guidelines for purposes of code selection, according to the rule.