Pulmonology Coding Alert

New regulations went into effect in March.

Practices that have been frustrated about the vast restrictions barring them from reporting telehealth services got some good news on March 13. That’s when CMS expanded coverage of telehealth services across the board to ensure that Medicare patients don’t have to risk their health to visit doctors’ offices, potentially subjecting themselves to coronavirus. Instead, Medicare beneficiaries can see their practitioners via telehealth and the MACs will reimburse the practices for such visits temporarily to account for the COVID-19 emergency.

Background: In the past, only certain visits were payable via telehealth, and only for beneficiaries in rural areas whose telehealth services took place at healthcare offices. Now, CMS will reimburse even if the patients are in their homes during the telehealth visits.

In addition, CMS won’t closely restrict the type of device used for the telehealth visit. Instead, patients can use their computers or smartphones to access face-to-face telehealth services. “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,” said CMS Administrator Seema Verma. “Clinicians on the frontlines will now have greater flexibility to safely treat our beneficiaries.”

Know Which Codes to Use

Keep in mind: 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 Pulmonology Coding Alert for more information.

If you perform a telehealth visit and you plan to bill your Part B payer for it, you’ll report these services using the same codes you would if you were seeing the patient in your office. For instance, if you see a patient via smartphone for an established patient E/M visit, you will report a code from the 99211-99215 series (Office or other outpatient visit for the evaluation and management of an established patient…).

Example: A 72-year-old patient contacts your office with an exacerbation of COPD. She has been short of breath and is coughing up more phlegm than usual, but is afraid to come to the office because she is practicing social distancing. The physician performs a telehealth visit with her that includes an expanded problem focused history and medical decision making of low complexity. The physician prescribes a course of Levaquin and prednisone to treat the COPD flare up. For this visit, you would report 99213.

These services are not restricted to physicians, CMS said. Practitioners such as physician assistants and nurse practitioners can report them also.

Although CMS is not requiring practices to use modifiers on codes that you report for telehealth services, the agency does note that there are three scenarios when you should use a modifier on these claims, according to a March 17 FAQ document that CMS issued, advises Carol Pohlig, BSN, RN, CPC, ACS, senior coding and education specialist at the Hospital of the University of Pennsylvania:

• When a telehealth service is furnished via asynchronous (store and forward) technology as part of a federal telemedicine demonstration project in Alaska and Hawaii, use modifier GQ (Via asynchronous telecommunications system).
• When a telehealth service is billed under critical access hospital (CAH) Method II, use modifier GT (Via interactive audio and video telecommunication systems).
• When telehealth service is furnished for purposes of diagnosis and treatment of an acute stroke, use modifier G0 (Telehealth services for diagnosis, evaluation, or treatment, of symptoms of an acute stroke).

Virtual Check-ins Are Different

If, instead of a formal telehealth visit, your pulmonologist has a brief discussion with an established patient to determine whether they need more comprehensive services, you can report a virtual check-in rather than billing a telehealth service. Use these codes for such visits:

• G2012 (Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion): This code covers real-time, synchronous telephone interactions.
• G2010 (Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment): You’ll use this code if the patient sends video, images, or other kinds of data transmissions (such as information from a monitor) for your provider to evaluate.

Resource: To read the fact sheet about this change, visit the CMS website at https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet.