Orthopedic Coding Alert

Here’s how telehealth and other virtual services differ.

Changes to coding and policy are flying fast and furious since the onset of COVID-19.

One entity that’s been making a lot of changes quickly lately is the Centers for Medicare & Medicaid Services (CMS), which has been forced to issue coding and billing guidelines far (far) more often than it normally does. These are contained in an emergency Interim Final Rule, which CMS was compelled to issue to respond to this unprecedented healthcare crisis.

Check out the latest round of changes CMS has decided on with regard to coding telehealth services — and stay tuned for more information as it becomes available.

Interim Final Rule Clarifies Telehealth Changes

CMS issued a pair of press releases in addition to an Interim Final Rule published in the Federal Register. (https://www.cms.gov/files/document/covid-final-ifc.pdf). “These changes 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,” explains CMS Administrator Seema Verma. The most up-to-date list of coronavirus waivers and flexibilities can be found at: https://www.cms.gov/about-cms/emergency-preparedness-response-operations/current-emergencies/coronavirus-waivers.

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. Providers are now capable of performing evaluation and management (E/M) office services, among a plethora of other services, using a virtual form of communication.

In this first article of a two-part telehealth suite, we’re going to focus on the coding guidelines surrounding Medicare telehealth services. Read on to get answers to your top questions.

Distinguish Medicare Telehealth From Other Services

Telehealth, telemedicine, and patient portal interactions between practitioner and patient via a virtual means of communication can be divided into four forms of service, as defined by Medicare Part B:

• Medicare telehealth visits,
• Virtual check-ins,
• E-visits, and
• Remote monitoring.

Without a proper distinction, it’s easy to confuse or overlap the services provided within each respective option. First, you’ll want to understand what’s needed to code a virtual service as a Medicare Part B telehealth visit. These visits are designated for patient encounters that would typically occur in-person. Patients may communicate with a practitioner from a healthcare facility or, most typically, from within their own home, as a result of the COVID-19 exceptions.

However, in order for a visit to qualify as a Medicare telehealth visit, the patient must use “an interactive audio and video telecommunications system that permits real-time communication between the distant site and the patient at home,” according to a CMS release (https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet).

Meeting the requirements for a telehealth service can most easily be achieved using a smartphone and an app. There are also HIPAA-compliant apps that are integral to many electronic health record (EHR) systems, in addition to standalone apps, such as Doxy.me and Chiron. Furthermore, the COVID-19 expansions of services and HIPAA waivers now allow practices to use more common interactive applications such as Facetime and Skype. These services will be reimbursed at the same rate as an in-person visit.

Note: When the COVID-19 exceptions initially came out, CMS indicated that the patient must have an established relationship with the provider for a telehealth encounter. But the Interim Final Rule indicate that practitioners may provide telehealth services to new patients, in addition to established patients.

Elaborate on Medicare Coding Guidance

A typical Medicare telehealth visit, which simulates an E/M office/outpatient encounter, should be reported using the E/M office/outpatient visit code range 99201-99215. However, more than 80 services now qualify for Medicare telehealth billing, according to the Interim Final Rule. Some of these services include:

• Emergency department;
• Initial nursing facility and discharge;
• Inpatient neonatal and pediatric critical care;
• Critical care;
• Domiciliary, rest home, or custodial care; and
• Home visits.

You can download the entire code list of covered telehealth services from CMS at: www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.

Remember Modifier CS

CMS explains that you should append modifier CS (Cost-sharing for specified covid-19 testing-related services that result in an order for or administration of a covid-19 test) “on applicable claim lines to identify the service as subject to the cost-sharing wavier for COVID-19 testing-related services. For a complete breakdown of what E/M claims are eligible, read about the Families First Coronavirus Response Act at: https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-04-07-mlnc-se.

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 Radiology 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.