Pulmonology Coding Alert

Coverage is retroactive to March 1, 2020.

If you’ve talked to patients who are concerned about presenting for in-person pulmonary rehab visits, CMS may have just made those services a bit simpler to perform.

Background: On Oct. 14, CMS announced that it was adding 11 new services to the Medicare telehealth services list, retroactive to March 1, 2020. The declaration is effective for the duration of the public health emergency (PHE) for COVID-19. Keep in mind that Health and Human Services (HHS) Secretary Alex Azar recently extended the PHE for another 90 days, with the current expiration date of Jan. 21, 2021. The additions bring the number of allowed Medicare services via telehealth to 144.

Among the 11 new codes, you’ll find that G0424 (Pulmonary rehabilitation, including exercise (includes monitoring), one hour, per session, up to two sessions per day) is now billable via telehealth.

What this means: You’ll be able to ensure that patients keep up with their pulmonary rehab (PR) schedules by handling the visits via telehealth. That way, even patients too nervous to present in person can stay on track with their PR goals..

Remember to Document Thoroughly

Though administrative burdens have been greatly reduced during the pandemic, documentation still matters. Under the COVID-19 flexibilities, providers can document these telehealth services as if they were any other face-to-face encounter, with a few exceptions.

“A statement should be provided indicating the services were provided via telehealth,” said NGS Medicare’s Lori Langevin during the Part B payer’s webinar “Telehealth Services in the Age of COVID-19 for Part B Providers.” According to NGS guidance, the documentation and statement should include the following:

• A note that the care was administered via telehealth (and mode of communication: audio-only or audio and video)
• Patient location
• Provider location
• All providers and persons involved in the service and their roles
• Time-based care start and stop time or total time of the service

PR Requirements Must Still Be Met

Prior to reporting any PR codes, you must ensure that the visit meets Medicare guidelines. A physician should first evaluate the patient to determine functional limitations. Then, both the physician and respiratory therapist or physical therapist will implement the designed PR program. When performed by an outpatient hospital department, the reporting facility will have to designate the individual’s home as a provider-based department with the individual being registered as an outpatient. The qualified provider should be located in the hospital outpatient setting or temporary expansion sites, and the physician provides direct “virtual” supervision.

Remember that G0424 covers one hour of PR (a minimum of 31 minutes, up to 90 minutes), which must include monitored exercise, and allows for up to two PR sessions (a minimum of 91 minutes) per day per patient.

CMS does not assign any specific limit on the duration of the PR program, but the code should cover only up to 36 visits. However, CMS points that additional services may be appropriate in certain situations. You will encounter many documentation obstacles where your claim may fall and rebound. Follow these golden rules to foolproof your claims:

• Remember to submit supporting documentation for the patient’s condition to demonstrate the medical necessity of the pulmonary rehab.
• Your documentation must show that there is an improvement in exercise tolerance and decreased symptoms of the disorder. Your pulmonologist should also assess and record the patient’s progress toward short-term goals at the beginning, during, and at the end of PR.

Your pulmonary rehab program documentation should also include the following:

• Physician-prescribed exercise
• Psycho-social assessment
• Outcomes assessment
• An individualized treatment plan
• Education and training tailored to the patient’s needs

Remember to include all of these items in your documentation, just as you would for an in-person PR visit. Telehealth audits have begun, and reviewers want to ensure that you’re fulfilling documentation requirements even for visits that are taking place remotely.

Resource: To read more about the codes recently added to the telehealth list, visit the CMS website at www.cms.gov/newsroom/press-releases/trump-administration-drives-telehealth-services-medicaid-and-medicare.