Primary Care Coding Alert

Question: I know that, at the beginning of this year, the American Medical Association (AMA) introduced modifier 93 for audio-only telemedicine. Can you tell me how billing an office/outpatient evaluation and management (E/M) service with this modifier differs from billing 99441-99443?

AAPC Forum Participant

Answer: The AMA introduced modifier 93 (Synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system) for use effective Jan. 1, 2022, though it will not make its appearance in CPT^® until 2023.

Initially, an office/outpatient E/M service with modifier 93 appended and the telephone E/M codes 99441 (Telephone evaluation and management service by a physician or other qualified health care professional … 5-10 minutes of medical discussion), 99442 (… 11-20 minutes of medical discussion), and 99443 (… 21-30 minutes of medical discussion) seem to represent similar services delivered via audio-only technology. However, there are at least two indications that it’s inappropriate to report an office/ outpatient E/M service with modifier 93 appended and you must report a telephone E/M code instead.

First, audio-only office/outpatient E/M codes 99202-99215 are not among those which meet the Medicare telehealth requirements per the Medicare Physician Fee Schedule.

Second, per CPT^® Appendix P, codes 99202-99215 must be provided using “interactive telecommunications equipment that includes, at a minimum, audio and video” (emphasis added). Thus, CPT^®, like CMS, does not seem to consider office/outpatient E/M services reportable when only using audio technology, leaving the telephone E/M codes as the codes of choice in such situations. That said, you may still want to consult your Medicare Administrative Contractor (MAC) or private insurance company representatives to find out their preferred way to document audio-only E/M services.