Practice Management Alert

Hint: The PHE expands access, but the de facto billing requirements don’t change too much.

Understanding how to code telehealth is crucial to being paid for virtual services rendered.

A typical Medicare telehealth visit, which simulates an evaluation and management (E/M) office/outpatient encounter, should be reported using the E/M office/outpatient visit code range 99201-99215. However, the March 30 press release outlines more than 80 services that will qualify for Medicare telehealth billing. 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 the Centers for Medicare & Medicaid Services (CMS) here: www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.

General rule: Report the respective E/M code for the location that the telehealth service would have taken place as though the PHE were not in effect.

E/M coding note: On page 141 of the interim final rule, CMS explains that your E/M level selection may be based on medical decision making (MDM) or time. This is similar to the upcoming changes to E/M reporting for the 2021 calendar year with two distinct differences. First, MDM coding will be based on the current definition of MDM and the existing MDM tables. Similarly, for time-based coding you should refer to the typical times associated with the office/outpatient E/M codes.

Keep This Billing Guidance in Mind

With respect to telehealth services billing, CMS outlines that the Office of Inspector General (OIG) will provide “flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.”

Of course, knowing the ins-and-outs of individual payer policy is crucial. Some payers are offering differing guidance on how to bill these services appropriately.

“In order to fully understand how this translates to your practice, you need to first check payer policy. One common assumption is that you have to submit an appeal when the copay is not covered by the payer following reimbursement. However, that’s only true if your local carrier is picking up the copay. I’ve yet to see this be the case, but you’ll want to make sure to confirm that policy in writing,” says Marie Popkin, CPC, CMCS, BSM, ProFee Auditor at HCCS HIM Services in Fort Myers, Florida.

Disclaimer: Information related to COVID-19 is changing rapidly. This information was accurate at the time of writing. You can also refer to payer websites, CMS (www.cms.gov), CDC (www.cdc.gov), and AAPC’s blog (www.aapc.com/ blog) for the most up-to-date information.