Oncology & Hematology Coding Alert
Update Your Telehealth Coding Tactics with This Q&A
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. “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 oncology coding? To answer that question, here is a brief overview of the three different types of telehealth services, along with the codes that may come into play when Medicare patients reach out to your oncologist with their health questions and concerns. Start by Checking Out These Virtual Check-In Questions What is virtual check-in? Virtual check-in codes document 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 receive the service? CMS also released a fact sheet on March 17, 2020 indicating “Virtual check-in services can only be reported when the billing practice has an established relationship with the patient.” The same notice also seems to take into account the circumstances at hand and has also admitted, “It is imperative during this public health emergency that patients avoid travel, when possible, to physicians’ offices, clinics, hospitals, or other health care facilities where they could risk their own or others’ exposure to further illness. Accordingly, the Department of Health and Human Services (HHS) is announcing a policy of enforcement discretion for Medicare telehealth services furnished pursuant to the waiver under section 1135(b)(8) of the Act. To the extent the waiver (section 1135(g)(3)) requires that the patient have a prior established relationship with a particular practitioner, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency.” 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 modifiers? No modifiers are needed with these codes. What else should I know about this service? Make sure your documentation includes: 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 receive the service? Only established patients may receive these services. 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: Record the place of service = 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, 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. 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. 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: 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 Oncology 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.
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