Medicare Compliance & Reimbursement

Know the rules on ‘face-to-face’ care.

Telemedicine has quickly emerged as a great option for providers to reach patients struggling with chronic issues or whose geography impedes their ability to come in for a visit. If your practice is currently implementing this clinical method, it’s important that you take into account all that there is to consider when reporting a telemedicine code.

Definitions: A good place to start is by outlining the difference between telehealth (defined as any health service provided by telecommunications) and telemedicine (defined as any clinical service provided by telecommunications). Additionally, you’ll want to consider the array of nuanced guidelines and constantly changing code sets.

Tip 1: Stay Abreast of Telemedicine Coding Changes

“One of the greatest challenges facing telemedicine coding is that changes in technology typically occur faster than changes in coding,” says Kent Moore, senior strategist for physician payment at the American Academy of Family Physicians.

“CPT^® code change proposals are often generated and acted upon more than a year before the changes/new codes appear in CPT^®, and CPT^® itself is only published once a year. So, it’s easy to see how technology moves faster, leaving coders to wonder if a new telemedicine service fits an existing code or needs to be reported using an unlisted code,” Moore adds.

For example the Centers for Medicare and Medicaid Services (CMS) introduced two new HCPCS codes for 2019: G2012 (Brief communication technology-based service, e.g. virtual check-in...) and G2010 (Remote evaluation of recorded video and/or images submitted by an established patient...), which you can use when a provider is evaluating information to determine if a patient needs to be seen in the office.

In addition, CMS added two prolonged service codes, G0513 (Prolonged preventive service(s) … first 30 minutes ...) and G0514 (… each additional 30 minutes ...) to the telehealth services’ list.

One way to stay current with telemedicine codes is to consult Appendix P in your CPT^® manual. Documenting any service listed there when provided via telemedicine is as easy as appending modifier 95 (Synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system). You will also need to add place of service (POS) code 02 (Telehealth) to your claim to indicate that the provider is at the distant site (as opposed to the originating site where the patient is located).

Modifier reminder: As of January 1, 2018, unless you are billing claims from a critical access hospital (CAH) under method II for institutional claims, you will no longer need to apply modifier GT (Via interactive audio and video telecommunication systems) to a Medicare telehealth claim. But modifier GQ (Via asynchronous telecommunications system) is still required for asynchronous communication when appropriate, reminds Mary I. Falbo, MBA, CPC, CEO of Millennium Healthcare Consulting Inc. in Lansdale, Pennsylvania.

Tip 2: Know When It’s Not Telemedicine

While telemedicine can involve the use of telephone communication, two groups of telephone E/M codes are not regarded as telemedicine.

Review: Codes 99441 through 99443 (Telephone evaluation and management service by a physician or other qualified health care professional … provided to an established patient, parent, or guardian …) and 98966 through 98968 (Telephone assessment and management service provided by a qualified nonphysician health care professional to an established patient, parent, or guardian …) are not regarded as telemedicine because CPT^® does not regard them as being “face-to-face” services.

The same is true for 99444 (Online evaluation and management service provided by a physician or other qualified healthcare professional … using the Internet or similar electronic communications network), which is also regarded as non-face-to-face and would also not be defined as telemedicine by virtue of its asynchronous nature.

Resource: Find Medicare’s booklet on telehealth services at www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/downloads/TelehealthSrvcsfctsht.pdf.