General Surgery Coding Alert

Your practice can currently offer 99441 (Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services …; 5-10 minutes of medical discussion), 99442 (… 11-20 minutes of medical discussion), or 99443 (… 21-30 minutes of medical discussion) as telephone/audio-only services if they are conducted by physicians or other qualified healthcare professionals (QHPs), as the descriptor states. However, Medicare coverage of 99441-99443 expires with the PHE plus 151 days.

Providers can also offer “certain counseling behavioral health care and educational services” as audio-only, such as 99497/+99498 (Advance care planning… first 30 minutes/each additional 30 minutes…) and G0438/G0439 (Annual wellness visit… initial visit/subsequent visit), according to the Centers for Medicare & Medicaid Services (CMS). These will be available through the end of 2023.

Remember: Physicians and QHPs must meet and follow current CPT^® guidelines for the services. 

Modifier alert: For qualifying audio-only services, you can select CPT^® modifier 93 (Synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system).

Post-PHE: “Following the 151-day post-PHE extension period, CMS will once again assign the telephone E/M services a ‘bundled’ status, which means Medicare will no longer separately pay for them,” says Kent Moore, senior strategist for physician payment at the American Academy of Family Physicians.

Anticipate the Future of E-Visits

You may be wondering whether e-visit codes will become obsolete post-PHE, but there’s likely no reason to expect these codes will go away or that payers will stop reimbursing for them.

E-visit codes: An e-visit is a patient-initiated digital encounter that takes place through a secure online portal. There are two sets of codes, one is for encounters between a patient and physician:

• 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)
• The other is for encounters between a patient and another QHP:
• 98970 (Qualified nonphysician health care professional online digital assessment and management, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes)
• 98971 (…11-20 minutes)
• 98972 (… 21 or more minutes)

Why are they here to stay? Codes 99421-99423 were actually added to CPT^® prior to the pandemic. This code set was part of the 2020 MPFS, which means they were thought up and published well before lockdown. “Furthermore, [the] PHE has not really impacted how the codes are delivered. They were online digital E/M codes when they were created, they still are, and they will continue to be after the PHE ends,” Moore says.

Caveat: When you bill these codes, make sure the physician documents the following:

• Proof the encounter was not initiated by the doctor
• Patient location
• Chief complaint/reason for encounter
• Justification for services
• Pertinent history and exam
• Medical decision making
• Applicable diagnoses
• Duration of encounter

Note: You will also need to document that the service did not lead to a related, separately reported E/M service within seven days of the initial online digital service. If that happens, you must bundle the work involved in 99421 into the more comprehensive E/M service, and bill only that code.

Global period: “If the [digital] inquiry is related to a surgical procedure within a global period, then the service is not reported,” says Natalie Ruggieri-Buzzelli, CPC, CGSC, HIM, coding specialist at the Hospital of the University of Pennsylvania.

Expect Addition of Some Services, Extension of Others

According to the 2023- Medicare Physician Fee Schedule (MPFS) final rule, several emotional/behavior assessments — as well as psychological and neuropsychological testing and evaluation services — have been added to the Medicare Telehealth List on a Category 3 (temporary) basis (see www. cms.gov/medicare/ medicare-general-information/telehealth/ telehealth-codes). They will be on the list through the end of 2023 or 151 days after the PHE ends, whichever is later. Since the PHE ended on May 11, 2023, you can expect the extension to last through the end of the year.

Remember: Many payers follow Medicare’s example, so what Medicare does in terms of coverage can help you measure your reimbursement expectations.

Revert to Previous Place of Service Codes

For 151 days following the end of the PHE, CMS is continuing to allow providers to bill for place of service (POS) as if the service was provided in-person, which means you do not need to use specific POS codes for telehealth. However, you must be mindful of the location of the provider rendering the services, as local state restrictions for rendering medical care across state lines — and practice scope limitations, along with payer rules and requirements — may limit your ability to bill out-of-state patients for telehealth services.

Post-PHE: On the 152nd day after the PHE’s end — October 10, 2023 — providers will need to indicate the appropriate POS code. CMS has finalized two options for continued use after the PHE:

• POS 02 (Telehealth provided other than in patient’s home)
• POS 10 (Telehealth provided in patient’s home)

Coming: The CPT^® Editorial Panel announced at an earlier meeting that there will be a new E/M code set in 2025 specifically for telehealth visits instead of using a POS code to identify them.