ED Coding and Reimbursement Alert

Watch Appendix P for applicable codes.

How CPT^® should capture and report telemedicine services has been under review for many years. 2017 finally brings a decision. Read on to learn what this means for Emergency medicine.

As telemedicine technology continues to improve, there has been an increasing demand for an accepted mechanism to identify and report services provided by a remote physician. The CPT^® Editorial Panel has considered this issue for many years, says David A. McKenzie, CAE, Reimbursement Director for the American College of Emergency Physicians in Irving TX. 

Various concepts have been considered over the past decade, before a joint CPT^® and RUC Telehealth Services workgroup was convened to make a recommendation on how best to move forward.  Among the options considered were creating a separate set of telemedicine codes to describe services or procedures provided using telemedicine technology and adopting a modifier approach, which could be appended to existing codes to signify the service was provided via telehealth technology.

The release of the 2017 CPT^® book unveils the decision. CPT^® will take the modifier approach. Modifier 95 (Synchronous telemedicine service rendered via a real time interactive audio and video telecommunications system) is now available for use. CPT^® modifiers are intended to be used to respond to payment policy requirements established by other entities (such as regulatory requirements and payer requirements).

The modifier descriptor specifies that the service must be synchronous, meaning in real time, for correct application. The qualified provider must be using real time audio and video telecommunications between the patient and the distant site in which they practice, and the totality of the information exchanged must be commensurate with the key components or other requirements to have reported the service or procedure as if the distant provider were physically present with the patient.

The CPT^® Editorial Panel considered, but apparently chose not to include, a second new modifier for asynchronous (not real time interaction) services, perhaps because of a lack of specificity for the services with which the modifier would be used. CMS has had a HCPCS modifier, GT (Via interactive audio and video telecommunication systems) available for use, but this is a new modifier for CPT^®, says McKenzie.

Additionally, the 2017 CPT^® book added new Appendix P, which lists codes that may be used for reporting synchronous telemedicine services when using interactive telecommunications equipment that incudes, at a minimum, audio and video.  The codes listed in Appendix P will now be marked with a star symbol (H), where they appear normally in the book. For example, H 0188T (Remote real-time interactive video-conferenced critical care, evaluation and management of the critically ill or injured patient; first 30-74 minutes)

Appendix P includes codes describing the following types of service:

Psychiatric, psychotherapy,  psychoanalysis, pharmacy management, ESRD, ophthalmological remote imaging for detection of retinal disease, cardiovascular monitoring and telemetry, genetic or neurobehavioral assessments, medical nutrition, office, subsequent hospital, outpatient consult, inpatient consult, subsequent nursing facility, prolonged services, behavioral change interventions and transitional care management codes.

Of note: No ED E/M or observation codes appear in Appendix P.

The codes selected for inclusion were based on a search of payer policy requiring the use of the HCPCS Level II synchronous modifier with CPT^® codes.  The ED codes did not come up anywhere in those payer policies so were not included in Appendix P.  Perhaps they can be added in future years with evidence that ED services are widely recommended for performance via synchronous real time communication, McKenzie explains.