Podiatry Coding & Billing Alert

During this PHE, both new and established patients can receive Medicare telehealth visits.

Due to the outbreak of the novel coronavirus (COVID-19), Medicare has relaxed its telehealth regulations to better facilitate healthcare for those impacted by the COVID-19 pandemic for the duration of this national public health emergency (PHE), under Waiver 1135.

Don’t miss: The Centers for Medicare & Medicaid Services (CMS) issued a series of press releases (March 17 and March 30) in addition to an Interim Final Rule published in the Federal Register on April 6. (https://www.cms.gov/files/document/covid-final-ifc.pdf).

How will these telehealth changes impact your podiatry practice? “Many states have shelter-in-place orders, meaning people can only leave their homes for the essentials,” says Arnold Beresh, DPM, CPC, CSFAC, in West Bloomfield, Michigan. “Podiatrists should only be in their offices to treat patients with post-op care and those with the need for diabetic ulcer care. However, some ulcer care may be able to be treated by telemedicine, if there is no need of immediate care for debridement.”

Podiatrists may also need to see patients in the office if the care exceeds that of telehealth, such as severe sprains, possible fractures, and lacerations, etc., Beresh adds.

In this two-part series, you will first take a look at Medicare telehealth visits. Then, in part two, you will take a look at the other forms of “virtual services”, as defined by Medicare Part B.

Master Medicare Telehealth Visits

FAQ 1: What are Medicare telehealth visits?

Answer: A Medicare Part B telehealth visit is designated for patient encounters that would typically occur in-person. Patients may communicate with a practitioner from a healthcare facility or from within their own home as a result of the COVID-19 exceptions.

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 CMS in its March 17 press release. Meeting the requirements for a telehealth service can most easily be achieved using a smartphone and an app. There are HIPAA-compliant apps that are integral to many EHRs and there are standalone apps, such as Doxy and Chiron.

Don’t miss: The recent expansions of services and HIPAA waivers that have been provided allow practices to use communications such as FaceTime and Skype during the COVID-19 PHE.

See Which Patients Can Receive Medicare Telehealth Visits

FAQ 2: Who can receive Medicare telehealth visits?

Answer: Usually, only established patients may receive Medicare telehealth visits. 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.

Report These Codes For Medicare Telehealth Visits

FAQ 3: How should I report Medicare telehealth visits?

Answer: CMS had an original list of services for a typical Medicare telehealth visit. Examples of codes on this original list included 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).

Important: Recently, the Interim Final Rule added more than 80 new services to be covered as Medicare telehealth visits on an interim basis during the COVID-19 PHE. You can find the entire list of covered telehealth services here: www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.

Take a look at some of the newly added interim codes: (Note: This is not an exhaustive list.)

• Emergency department visit codes 99281-99285
• Initial and subsequent observation and observation day management codes 99217; 99218 99220; 99224-99226; and 99234-99236
• Initial hospital care and hospital discharge day management codes 99221-99223 and 99238-99239
• Critical care codes 99291 and +99292
• Home visit codes 99341-99350

Check Out Interim Rules for Leveling Telehealth E/M Services

FAQ 4: How do we level office/outpatient E/M visits when they are furnished via Medicare telehealth during this PHE?

Answer: On an interim basis during this COVID-19 PHE, CMS has revised its policy so now office/outpatient E/M level selection for office/outpatient E/M telehealth visits can be based on medical decision making (MDM) or time. Time is defined as all of the time associated with the E/M on the day of the encounter. The requirements regarding documentation of history and the physical exam have been removed.

This change is very similar to the upcoming 2021 E/M changes for office/outpatient E/Ms. However, with this revision for telehealth, CMS will keep the current MDM definition and existing MDM tables. For time-based coding, you should refer to the typical times associated with the office/outpatient E/M codes.

Editor’s note: Each private payer has instituted their own rules surrounding telehealth claim coding and billing. Check with your non-Medicare Part B payers for further elaboration and guidance.

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 Podiatry Coding and Billing Alert for more information. You can also refer to payer websites, CMS (cms.gov), CDC (cdc.gov), and AAPC’s blog (https://www.aapc.com/blog/) for the most up-to-date information.