Oncology & Hematology Coding Alert

Question: Due to the COVID-19 pandemic, our providers are performing mostly telehealth video visits. Is the documentation requirement the same for performing an in-person visit, especially with the physical examination elements? If the patient is new or the oncologist performs a preventive visit, are the physical examination components the same as it would be for an in person visit? Many of our providers are documenting “physical exam deferred due to the virus” for an annual checkup.

California Subscriber

Answer: For an outpatient or office E/M telehealth service, you will base the documentation on total time or on MDM. The requirements for MDM have not changed under this directive from CMS in the Interim Final Rule with Comments period (“IFC”) during the public health emergency (“PHE”), so be very careful that the documentation supports the level of MDM your provider selects. Also, watch out if you are using total time of say 60 minutes for a minor problem. Payers will be scrutinizing the documentation for higher level of services after PHE is over.

Medicare preventative visits on the approved telehealth code list are Medicare Annual Wellness Visits (“AWV”). These are defined as HCPCS codes G0438 (Annual wellness visit; includes a personalized prevention plan of service (PPPS), initial visit); and G0439 (Annual wellness visit, includes a personalized prevention plan of service (PPPS), subsequent visit). These visits require, in part, vital signs be reported leveling providers uncertain how that element could be captured in a telehealth situation, especially now since the AWV may be audio-only in come cases. However, on the CMS Office Hours tele/webcast May 14, 2020, a participant asked (30:15 minute mark of the presentation) if the reporting of vital signs requirement could be self-reported by the patient. CMS did indicate some of the information could be reported by the patient lending to the potential solution to that hurdle. The Initial Preventive Physical Examination (“IPPE”), and it is not on the telehealth list currently as of this writing and only mentioned in the IFC pertaining to a supervision requirement of teaching physicians, so that code should not be delivered via telehealth. Commercial and State Medicaid carrier policies vary during PHE. Seek guidance from those sources to determine if and how preventive visits of differing types may or may not be rendered when the patient does not present ‘in-person.’ The tele/webcast URL is here: https://www.cms.gov/files/audio/covid19officehours05142020.mp3.

Smart: Also, you should be accessing the COVID-19 policies of your major payers — especially Medicaid as their documentation requirements may also include such things as: a notation in the medical record that indicates that the service was provided during PHE, via telehealth, the technology used, and the physical location of the patient, distant and the originating site. Most requirements seem to include the CPT^® code for the service rendered via telehealth be recorded in the patient’s medical record. If you are billing the quick e-visits or virtual visits, the patient must also give verbal agreement to the service, but you better make sure that is documented. The consent may be obtained by ancillary staff and only annually to help easier operationalizing this component to not always fall on the provider.