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shanamarie

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I read somewhere that CMS stated that we could bill telemedicine office visits on total time or mdm like it will be in 2021, but can’t seem to find it now. Did anyone else see this and if so can you please post a link?
 
Telemedicine is billed with E/M codes. E/M codes may always be billed on time, provided > 50% of time is counseling/coordination of care. Telemedicine is pretty much 99% spent counseling/coordination of care. The provider must put the total time and note > 50% in counseling/coordination of care. I have not seen any guidance or advice changing the requirements to allow only using MDM during this situation. So far, we have coded all telemedicine based on time.
 
The proposed changes to E&M documentation requirements for 2021 would allow the use of either total time or MDM for selection of the E&M level (on office visit codes only). These proposals have not yet been finalized, and I'm not aware of any guidance as to how the new rules will apply to telehealth/telemedicine.

There are a number of articles you can find describing the new guidelines, as well as a recent webinar here on the AAPC site. The detailed information can be found the CMS 2020 Physician Fee Schedule Final Rule if you with to go directly to the source.
 
shanamarie said:
I read somewhere that CMS stated that we could bill telemedicine office visits on total time or mdm like it will be in 2021, but can’t seem to find it now. Did anyone else see this and if so can you please post a link?
Click to expand...
You are correct. Interim final rule CMS-1744-IFC states, "On an interim basis, we are revising our policy to specify that the office/outpatient E/M level selection for these services when furnished via telehealth can be based on MDM or time, with time defined as all of the time associated with the E/M on the day of the encounter; and to remove any requirements regarding documentation of history and/or physical exam in the medical record. This policy is similar to the policy that will apply to all office/outpatient E/Ms beginning in 2021 under policies finalized in the CY 2020 PFS final rule. It remains our expectation that practitioners will document E/M visits as necessary to ensure quality and continuity of care. To reduce the potential for confusion, we are maintaining the current definition of MDM. We note that currently there are typical times associated with the office/outpatient E/Ms, and we are finalizing those times as what should be met for purposes of level selection. The typical times associated with the office/outpatient E/Ms are available as a public use file at https://www.cms.gov/Medicare/Medica...S-Federal-Regulation-Notices-Items/CMS-1715-F."

I hope that is not too late to be helpful.
Cindy
 
I have a different question - can anyone tell me if a patient does not have the ability to use audio video for a telehealth visits and we have to use the phone in place of the face to face visit in the office - can we bill this with the telehealth codes (EM) or do we need to use the telephone codes. CMS has stated that the telehealth codes are to be used for the visits that would normally be done in the office which this one was but this patient did not have the internet. Telephone codes are not listed under the telehealth codes. CMS has also stated that those who do not have this technology can still be billed under telehealth. Can we bill these with the telehealth EM codes? of do we need to use the Telephone codes?
 
For CMS, it is definitely 99441-99443 or G2012 if no video. Most private carriers are also stating no video, no E/M. Some carriers (Cigna) have stated audio only may be billed with E/M, but that is NOT the official CMS guidance.
Telephone only is 99441-99443 unless you have written official guidance from a private carrier stating otherwise.
 
shanamarie said:
I read somewhere that CMS stated that we could bill telemedicine office visits on total time or mdm like it will be in 2021, but can’t seem to find it now. Did anyone else see this and if so can you please post a link?
Click to expand...

Hi this is what I found and also attached what I could find from CMS. Hope this helps.
 
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