General Surgery Coding Alert

Learn CMS expanded coverage during pandemic.

 If healthcare providers from your general surgery practice use telephone or email for patient monitoring during the COVID-19 public health emergency (PHE), you have new ways to bill for that service, according to CMS.

In addition to expanded telehealth billing discussed in last month’s General Surgery Coding Alert (Vol. 21, No. 6), we have news for you about how to bill for other types of patient contact your surgeons or other healthcare providers might use during the pandemic. These are ways that the practitioner may respond to the patient’s concern by telephone, audio/ video, secure text messaging, email, or use of a patient portal.

Look to Telephone Codes

If your practice’s healthcare providers have an audio-only interaction with a patient (a phone call), you should not use the patient E/M visit codes that you’d use for telehealth as described last month in “Master New Guidance for COVID-19 Telehealth Exceptions.” Instead, you should turn to the telephone codes.

“Medicare is covering the telephone CPT^® codes and is reimbursing them at rates comparable to E/M services during the PHE,” says Terri Brame Joy, MBA, CPC, COC, CGSC, CPC-I, billing specialty subject matter expert at Kareo in Irvine, Calif.

Here’s why: CMS states in the interim final rule published in the Federal Register on April 6 that the goal of reducing exposure risks associated with the COVID-19 PHE may warrant a prolonged, audio-only communication between practitioner and patient, especially if the patient doesn’t have access to two-way audio and video technology required for a telehealth visit.

In the interim final rule, CMS states that telephone services are temporarily covered for both new and established patients for the duration of the PHE using the following codes:

• 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 …) in increments of 5-10 minutes, 11-20 minutes, and 21-30 minutes. Use these codes for nonphysician professionals.

• 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 …) in increments of 5-10 minutes, 11-20 minutes, and 21-30 minutes for physicians, physician assistants (PAs), and nurse practitioners (NPs).

“Because these are not telehealth, they are not billed with any telehealth signifiers or rules,” says Joy. “You should report these codes with [place of service] POS 11 (Office) or 22 (Outpatient hospital) and the provider’s billing service location,” she says.

Tip: The CMS list of covered telehealth services includes an indicator if you can bill the code for an audio-only encounter.

Understand Virtual Check-In

In addition to telephone calls for more extensive communication, Medicare is also covering virtual check-ins. These services involve a brief communication between patient and provider, typically from the patient’s own home. Like the telephone codes, billing for these services does not require both audio and video communication.

Use the following codes for virtual check-ins:

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): This code covers a service via telephone (patient phoning you to provide an update or minor issue) or email exchange.

G2010 (Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, 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): You’ll use this code if the patient sends video, images, or other kinds of data transmissions (such as information from a monitor) for your provider to evaluate. These are typically “store and forward” services in which a patient sends a practitioner an image or video and the practitioner responds at a subsequent date.

During the COVID-19 PHE, Medicare will cover these services for both new and established patients, even though the code may indicate that the service is for an established patient. CMS also broadens the scope of providers allowed to bill these codes beyond “qualified health care professional who can report evaluation and management services.” As with expanded coverage for telephone codes, these changes reflect the need to limit exposure risk during the COVID-19 pandemic.

Code E-Visits for Patient Portal Communication

A third type of virtual service Medicare will cover during the PHE is an e-visit. On the surface, these services may look similar to virtual check-ins. However, the difference

lies with the channel of communication. “E-visits (digital communication) take place through a secure online portal,” relays Natalie Ruggieri-Buzzelli, CPC, CGSC, HIM coding specialist at the Hospital of the University of Pennsylvania.

E-visits may be performed by physicians or advanced practice providers (APPs) using one of the following three time-based E/M codes:

• 99421 (Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes)
• 99422 (…11-20 minutes)
• 99423 (… 21 or more minutes)

You can report these codes only if the e-visit does not result in a visit, including a telehealth visit, according to the CMS interim final rule.

New or established: CMS also states in the rule that these communication-based technology services “can be furnished to both new and established patients,” contrary to the code definition.

Capture Remote Monitoring

The fourth type of virtual care involves remote monitoring. This can include remote heart monitoring, blood pressure monitoring, blood sugar monitoring, etc., in addition to providing ongoing feedback to the patient.

You can report the service using codes in the ranges 99453-99454 (Remote monitoring of physiologic parameter(s) (eg, weight, blood pressure, pulse oximetry, respiratory flow rate), initial …) and 99457-99458 (Remote physiologic monitoring treatment management services, clinical staff/ physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month …), in addition to code 99091 (Collection and interpretation of physiologic data (eg, ECG, blood pressure, glucose monitoring) digitally stored and/or transmitted by the patient and/or caregiver to the physician or other qualified health care professional, qualified by education, training, licensure/regulation (when applicable) requiring a minimum of 30 minutes of time, each 30 days).

For the duration of the COVID-19 PHE, CMS states that you can report these services for new patients as well as established patients. The rule also modified the number of days that data must be collected from the required 16 days to fewer than 16 days in a 30-day period as long as the other code requirements are met.

Resource: You can access the interim final rule in the April 6 Federal Register at www.govinfo.gov/content/pkg/FR-2020-04-06/pdf/2020-06990.pdf.

Editor’s note: Information related to COVID-19 is changing rapidly. This information was accurate at the time of writing. Be sure to stay tuned to future issues of General Surgery Coding Alert for updates. You can also refer to payer websites, CMS (cms.gov), CDC (cdc.gov), and AAPC’s blog (www.aapc.com/blog) for the most up-to-date information.