ED Coding and Reimbursement Alert

Remember the importance of modifier 95, Part B reps noted.

Although you’ve likely been performing telehealth visits under the new, temporary regulations for nearly a year now, there’s no question that EDs still face confusion when reporting services under the public health emergency (PHE). But Part B reps recently offered some helpful telehealth coding and billing advice that can allow you to bring in reimbursement faster by coding correctly the first time you submit these claims.

The Q&A session took place during Part B payer NGS Medicare’s Jan. 14 webinar, “COVID-19 Telehealth Services.” NGS’ Lori Langevin reminded providers that the PHE has been extended through April 20, 2021, and therefore it’s important to ensure that your telehealth billing skills are still on the cutting edge.

Don’t forget: “On or after March 1, 2020 and for the duration of the PHE, you need to append modifier 95 (Synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system) to services performed via telehealth,” Langevin said. “Modifier 95 indicates to the payer that the service was telehealth and your payment will not be reduced. The place of service (POS) during the PHE is going to be equal to what it would have been if the visit had happened face to face.”

In addition, she said, when documenting telehealth services, remember to document the same way you would for any face-to-face patient encounter, “but also indicate that the visit took place via telehealth, along with the patient’s location, the provider’s location, the names of all persons participating in the telemedicine service, and their role in the encounter. For time-based services, you can document the stop/start time or the total time,” she said.

During the question-and-answer session, NGS’ Nathan L. Kennedy, Jr., CPC, CHC, CPPM, CPC-I, CPB, CPMA, provided answers to some of the most pressing questions practices had about telehealth and the PHE. Check out seven of them below.

1. Can GE Modifier Allow Residents to Report Phone Codes?

One participant asked whether residents can report 99441-99443 (Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian 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 …) if they use modifier GE (This service has been performed by a resident without the presence of a teaching physician under the primary care exception).

“These are telephone E/M services performed by physicians who normally bill Medicare, so this is not typically going to fall into a teaching physician-type service,” Kennedy said. “In a teaching physician setting, the teaching physician is overseeing the resident and must be there for the key portions of the service and must be available by audio and video technology, so by the definition of the codes for telephone services, that technically does not seem to fit.”

Caveat: If the resident is working under the primary care exception, they may be able to use those codes during the PHE, but the resident must meet strict guidelines to support billing these codes using the exception. Keep in mind, however, that this exception would not generally be applicable in the ED setting.

2. Can You Differentiate 99441 Series From 98966 Range?

Another participant wondered whether nurse practitioners and licensed clinical social workers (LCSWs) can report 98966-98968 (Telephone assessment and management service provided by a qualified nonphysician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment ...) or if they should instead bill a code from the 99441-99443 range.

“A nurse practitioner would be able to use those codes [98966- 98968] or the 99441-99443,” Kennedy said. “The intent during the PHE is that nurse practitioners will use 99441-99443. Those codes have been established for those practitioners that can bill E/M services outside the PHE, but the way the PHE is set up they could bill for either set.”

However, he said, the LCSW would typically only report 98966-98968, since these providers can’t report 99441-99443. “If an LCSW is checking in with the patient and providing an assessment of the patient and how they’re doing in a PHE … it’s really a brief sort of visit to find out how they’re doing and see if anything can be addressed over the phone,” he added.