Notice from the newsroom press release from CMS.gov announcing the relaxation of the requirement for telehealth services to be audio/visual to allow audio only. Also expanding the covered Telehealth services. The guidance specifically states;
"Since some Medicare beneficiaries don’t have access to interactive audio-video technology that is required for Medicare telehealth services, or choose not to use it even if offered by their practitioner, CMS is waiving the video requirement for certain telephone evaluation and management services, and adding them to the list of Medicare telehealth services. As a result, Medicare beneficiaries will be able to use an audio-only telephone to get these services. "
A Link to this article and to the Medicare Telehealth Services is below.
I believe this explicitly states that 99211-99215 can be administered via telehealth or via audio only for those who cannot or do not choose to use telehealth platforms. All I have seen so far is an absence of guidance so if there is written guidance which invalidates this, please let me know.
I do not make that leap from Medicare beneficiaries are now covered for telephone evaluation and management services to bill those services with 99201-99215.
I still have not seen any CMS or Medicare guidance advising to bill audio only as 99201-99215. The links you provide state audio only is covered, but does not state to bill them 99201-99215. I have read several documents advising audio only is now covered, and the codes for that are 99441-99443.
https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf
Section L, questions 15, 24 & 31 all specify to use 99441-99443 for audio only.
https://www.ngsmedicare.com click on prominent COVID 19 banner, then Telehealth Services on left:
Telephone Evaluation and Management Visits
The March 30
Interim Final Rule with Comment Period added coverage during the Public Health Emergency for audio-only telephone evaluation and management visits (
CPT codes 99441, 99442 and 99443) retroactive to 3/1/2020. On 4/30/2020, a new Physician Fee Schedule was implemented increasing the payment rate for these codes. MACs will reprocess claims for those services that they previously denied and/or paid at the lower rate.
There are also a number of add on services (CPT codes 90785, 90833, 90836, 90838, 96160, 96161, 99354, 99355, and G0506) which Medicare may have denied during this Public Health Emergency. MACs will reprocess those claims for dates of service on or after 3/1/2020.
CMS even posted a YouTube MLN
. At 4:57, 11:14, 17:15 and especially 19:00, it is specified that audio only is covered with telephone evaluation & management, and should be billed 99441-99443.
I will note there are some counseling codes that typically require video that Medicare has waived and may be provided via audio only. I am not familiar with the nuances of this waiver as this is not a service we provide in my practice. I believe CMS has been clear with this. Audio only is covered with 99441-99443 for clinicians who may independently bill.