EM Coding Alert
Confused by the Current COVID-19 Telehealth Waivers? Here's What You Need to Know
CMS’ Interim Rule changes guidelines, adds to code list. On March 31, 2020, the Centers for Medicare & Medicaid Services (CMS) responded to the current COVID-19 public health emergency (PHE) by issuing an Interim Final Rule. The rule consolidated previous temporary rulings and added additional guidelines and clarification regarding telehealth’s role in the current pandemic. Here are the highlights of that rule to help you stay connected to your patients in the weeks and months to come. More Codes Added to the Medicare Telehealth Service List Some codes that became effective March 1, 2020 and that might come into play include: Go to www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes for the updated list. Guideline Waivers and Flexibilities for the PHE These changes to the current telehealth guidelines (which we outline in the next article in this issue) will remain in effect for the duration of the COVID-19 PHE: Location: Telehealth services may now be furnished to patients “wherever they are located, including in the patient’s home.” 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. “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 pediatricians office,” Donelle Holle, RN, president of Peds Coding Inc., and a healthcare, coding, and reimbursement consultant in Fort Wayne, Indiana, suggests. 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 …). Additionally, the Department of Health and Human Services’ Office of Civil Rights 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.” Consent: The Interim Final Rule allows for telehealth consent, which often must be obtained annually, to be “obtained at the same time that a service is furnished” and to be obtained by auxiliary staff under general supervision, not just by the billing practitioner, for the duration of the PHE. 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. This means “you should ALWAYS record your time in case you need to use it to level the care,” Holle advises. Payments: On March 1, 2020, Medicare began paying for telehealth services, “including office, hospital, and other visits furnished by physicians and other practitioners to patients located anywhere in the country, including in a patient’s place of residence,” the Interim Final Rule confirmed. This includes separate payments for 98966-98968, 99421-99423, 99441-99443, G2012, and G2061-G2063. Private payers: America’s Health Insurance Plans (AHIP), the trade association that represents private health insurance companies across the country, has announced they will match Medicare’s current waivers for its beneficiaries “in areas where inpatient capacity is under strain,” according to CMS Administrator Seema Verma. For a comprehensive list of private payer policies in response to the COVID-19 emergency, go to www.ahip.org/health-insurance-providers-respond-to-coronavirus-covid-19/. Coding alert: This information was accurate at the time of writing, but information related to COVID-19 is changing rapidly. Be sure to stay tuned to future issues of E/M Coding Alert for more information. You can also refer to payer websites, CMS (cms.gov), the Centers for Disease Control and Prevention (CDC) (cdc.gov), and AAPC’s blog (www.aapc.com/blog) for the most up-to-date information. And don’t forget that, once the state of emergency has been lifted, Medicare and many private payers will go back to most, if not all, the telehealth guidelines outlined in the next article.
EM Coding Alert
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