Ob-Gyn Coding Alert

Don’t assume this means you can use 99441-99443.

With the outbreak of the novel coronavirus (COVID-19), Medicare relaxed its telehealth regulations to facilitate healthcare for the elderly and others affected by the COVID-19 pandemic for the duration of the national public health emergency—which means you need to understand when, what is needed, and how to report these claims.

Background: Specifically, the purpose of the decision was to “allow seniors to communicate with their doctors without having to travel to a healthcare facility so that they can limit risk of exposure and spread of this virus,” according to Centers for Medicare & Medicaid Services Administrator Seema Verma. Keep in mind that most Medicaid programs have also adopted the use of these codes.

First let’s get on the same page: “Virtual visits” consist of 4 types of services:

• Telehealth visits (real-time audio and video),
• E-visits (online E/M visits),
• Virtual check-ins (assessments by telephone or other telecommunication device to determine whether an in-office encounter is needed for the patient’s concern),
• Telephone E/M visits (which are not covered by Medicare but may be covered by some private payers).

“We have implemented telehealth throughout the clinics and hospitals here, and it is working really well,” says Kaitlyn Eversole, CPC, CFPC, a coder in Indiana. “This keeps patients with acute illnesses at home and leaves open beds for those who need critical care.”

But what does that mean for ob-gyn coding? To answer that question, here is a brief overview of the different types of telehealth services, along with the codes that may come into play when Medicare patients reach out with their health questions and concerns.

Heads up: The Centers for Medicare & Medicaid Services (CMS) issued a press release on March 17, 2020 and another one on March 30, 2020, outlining new rules and policies surrounding extensions in telehealth billing during the COVID-19 virus emergency. The most up to date list of Coronavirus Waivers & Flexibilities can be found at https://www.cms.gov/about-cms/emergency-preparedness-response-operations/current-emergencies/coronavirus-waivers.

For information about which codes can be reported for Medicaid programs, check your local Medicaid websites for published information.

Break Down the Rules and Policies

Under normal circumstances, practitioners and patients would have to navigate through a series of requirements in order to meet the appropriate criteria for virtual telehealth services. But until further notice, many of these guidelines are completely dissolved. Evaluation and management (E/M) services, mental health counseling, home visits, and even preventative screenings are now capable of being performed via a virtual form of communication.

Furthermore, the March 30th press release added over 80 codes for nontraditional telehealth services which can now be billed under telehealth during this public health emergency (PHE).

Note: Initially, CMS indicated that the patient must have an established relationship with the provider for a telehealth encounter when the COVID-19 exceptions first came out. But the March 30th press release and instructions specifically indicate that practitioners may provide telehealth services to new patients in addition to established patients.

Start by Checking Out These Virtual Check-In Questions

What is virtual check-in? Virtual check-in is a documented brief communications between a patient and a provider to determine whether a patient’s condition requires further services. Reporting the service requires direct phone OR video communication between patient and provider unlike other telehealth visits.

Who can provide the service? Only providers who can perform and bill E/M services may bill for virtual check-ins.

How do I code the service? Use 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) for real-time, synchronous telephone interactions.

If the patient has sent video, images, or other kinds of data transmissions (such as information from a monitor) for your provider to evaluate, use 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).

And what about adding a modifier? No modifiers are needed with these codes.

What else should I know about this service? Make sure your documentation includes:

• Documented Patient Consent for the virtual check-in service
• Patient Location
• Chief Complaint or Reason for Encounter
• Justification for Telehealth Service
• Example: “Pt presents during the COVID-19 pandemic / federally declared state of public health emergency. This service conducted via (specify communication type). Patient is… (document the rationale for using this visit type- pt is immunocompromised, at risk of exposure...)”
• Pertinent History, Exam, Medical Decision Making
• Diagnosis AND
• Duration of Encounter

Next, Evaluate Telehealth E/M Visit Tips

What are telehealth E/M visits? The service describes patient-initiated communications through electronic health record (EHR) portals, secure email, or other digital applications.

Who can provide the service? See the coding information below.

How do I code the service? Use the CPT^® codes for Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days:

• 99421 if cumulative time during seven-day period is 5 to 10 minutes
• 99422 for 11 to 20 minutes; and
• 99423 for 21 or more minutes.

Record the place of service as the provider’s place of service code, and choose the codes based on the time spent as documented by the providers who can perform and bill for E/M services.

Use G2061 (Qualified nonphysician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 5-10 minutes), G2062 (… 11–20 minutes), or G2063 (… 21 or more minutes) according to time for QNHPs who cannot perform and bill for E/M services. However, note that these codes are not for use by clinical staff whose work would be included as part of the payment for the service when billed by the provider.

No modifiers are needed with these codes.

What else should I know about this service? Make sure physician documentation includes patient consent, patient location, chief complaint/reason for encounter, justification for telehealth services, pertinent history, exam, medical decision making, diagnosis and duration of encounter.

Next, Zero In On Telephone Codes

CMS also adds audio phone calls as covered services.

What are telephone E/M visits? These are non-face-to-face E/M services provided to the patient using the telephone.

Who can provide the service? A physician or other qualified health care professional, who may report E/M services.

How do I report this service? For telephone interactions, you should report:

• 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).

Finally, Master Medicare Telehealth Visits

What are these services? These are services that would generally be conducted face-to-face but that can also be furnished via “an interactive audio and video telecommunications system that permits real-time communication between the distant site and the patient,” according to the Medicare Telemedicine Health Care Provider Fact Sheet.

Who can receive the services? Usually, only established patients may receive these services. However, the Medicare 1135 waiver allows telehealth visits for new patients “for claims submitted during this public health emergency,” according to the Medicare Telemedicine Health Care Provider Fact Sheet.

Who can provide the services? “Distant site practitioners who can furnish and get payment for covered telehealth services (subject to state law) can include physicians, nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologists, clinical social workers, registered dietitians, and nutrition professionals,” according to the Medicare Telemedicine Health Care Provider Fact Sheet. Make sure you read the individual code descriptor closely for other provider limitations.

How do I code these services? The service must be listed in CMS’s list of telehealth services. Examples of common services that can be furnished via telehealth include 99201-99215 (Office or other outpatient visit for the evaluation and management of a new/established patient …), G0425-G0427 (Telehealth consultation, emergency department or initial inpatient …), and G0406-G0408 (Follow-up inpatient consultation … communicating with the patient via telehealth) according to the Medicare Telemedicine Health Care Provider Fact Sheet.

Do I need a modifier for these services? Telehealth visits for Medicare patients, per CMS telehealth guidelines, require that you append place of service (POS) code 02 (Telehealth) to indicate “the location where health services and health related services are provided or received, through telecommunication technology.”

In addition, depending on the way the service was furnished, you would append modifier GT (Via interactive audio and video telecommunication systems) or modifier GQ (Via asynchronous telecommunications system) for services provided by store-and-forward technology. Distant site practitioners billing telehealth services under the CAH Optional Payment Method II must submit institutional claims using the GT modifier.

Be sure to visit the Medicare Telemedicine Health Care Provider Fact Sheet in the CMS Newsroom at: https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet for more detailed information and the CMS Newsroom (https://www.cms.gov/newsroom) , the CDC (https://www.cdc.gov/) and WHO (https://www.who.int/) websites for updates as they are released on this topic regarding the allowances and special conditions during the COVID-19 pandemic / federally declared state of public health emergency.

Disclaimer: Again, 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 Ob-Gyn Coding Alert for more information. 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.