Health Information Compliance Alert

Question: Our practice has been utilizing telehealth to care for patients during the pandemic, but some patients prefer a chat via the phone instead. How do we report these phone-based visits?

Codify Subscriber

Answer: Although many physicians are performing visits via telehealth (which requires two-way synchronous real-time communication via audio-visual technology), not all patients are equipped to speak to their physicians this way, and some are instead requesting phone visits. Fortunately, during the public health emergency (PHE), the Centers for Medicare & Medicaid Services (CMS) also adds audio phone calls as covered services.

In black and white: “A broad range of clinicians, including physicians, can now provide certain services by telephone to their patients (CPT^® codes 98966 -98968; 99441-99443),” CMS says in a March 30 fact sheet.

For telephone interactions, you should report the following codes:

• 99441 (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; 5-10 minutes of medical discussion)
• 99442 (… 11-20 minutes of medical discussion)
• 99443 (… 21-30 minutes of medical discussion)

Example: An established patient calls the physician to discuss a recent asthma exacerbation. The provider discusses ways the patient can cut back on their current levels of strenuous physical activity. The total phone call time is 15 minutes.

How to code this: Code this as a telephone service using 99442, since the service meets the criteria that the patient is established and has initiated the call, and that a physician or other qualified healthcare professional has provided the service.

Keep in mind: Before using these codes, you must make sure services have not originated “from a related E/M [evaluation and management] service provided within the previous seven days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment,” per the code descriptors. Also, per pre-PHE guidelines, the patient must be established and must have initiated the contact before using the phone codes. Since these services represent non-face-to-face services, rather than “telehealth,” and are not on the list of services constituting audio-visual telehealth, do not append modifier 95 (Synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system) to phone services.

Resource: Review CMS guidance on telehealth during the PHE at www.cms.gov/files/document/covid-19-physicians-and-practitioners.pdf.