Practice Management Alert

Question: Even though the restrictions and mandates are being dropped across the country after the omicron surge, my practice is still doing a lot of appointments via telehealth. Is there a way to bill for these services even though there’s no physical exam component?

Maryland Subscriber

Answer: Even though the most recent surge is finally ebbing, the Centers for Medicare & Medicaid Services (CMS) made a provision in May 2020 that still applies, as long as the public health emergency (PHE) remains in effect.

Xavier Becerra, Secretary of Health and Human Services, renewed the PHE again Jan. 16, 2022, for 90 days, meaning it remains in effect until at least April 16, 2022.

Therefore, this CMS provision, part of the primary care exception, still applies: “Telephone E/M services (CPT^® codes 99441-99443), Transitional Care Management (CPT^® codes 99495-99496), and Communication Technology-Based Services (CPT^® codes 99421–99423 and 99452, and HCPCS codes G2010 and G2012). For office/outpatient E/M services furnished via telehealth, the E/M level selection can be based on medical decision making (MDM) or time, with time defined as all of the time associated with the E/M on the day of the encounter. We also removed any requirements regarding documentation of history and/or physical exam in the medical record.”

Find more information at www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf.