How to document and bill for telemedicine visits during COVID-19 emergency?

Due to the urgency to expand the use of technology to help patients who need routine care, and to keep vulnerable patients or patients with mild symptoms in their homes while maintaining access to the care they need, under the guidance of President Trump, CMS has broadened access to Medicare telehealth services.

Under the new 1135 waiver effective March 6, 2020, Medicare patients will be able to receive certain services at their home through telehealth, including evaluation and management visits, mental health counseling and preventive health screenings.  This waiver will be valid through the duration of COVID-19 Public Health Emergency.

The providers who can furnish and get reimbursed for covered telehealth services include:

  • Physicians
  • Nurse Providers
  • Physician Assistants
  • Nurse Midwives
  • Certified Nurse Anesthetists
  • Clinical Psychologists
  • Clinical Social Workers
  • Registered Dietitians
  • Nurse Professionals

The above services will be considered the same as in-person visits and will be paid at the same rate as regular, in-person visits. In order to render telemedicine services, a provider must have license in the state that the patient is located. To refer to your state specific guidelines please click here.

With regards to technology, the provider must use an interactive audio and video telecommunications system that permits real-time communication between the provider site and the patient at home. Considering ease-of-use and HIPAA compliance, some of the good platforms available for use (with no order of preference) include:

Regarding HIPAA, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency (Source: https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/index.html).  Facebook Live, Twitch, TikTok and similar video apps that are public facing should not be used to provide care virtually.  It is recommended that you check your state specific HIPAA guidelines as well.

There are three main types of virtual services that providers can provide to their patients, including:

ServiceApplicable CodesModifierPOSMediumPatient Workflow Documentation2, 3
TeleHealth99201 – 992051
99211 – 99215
For complete list of codes, click here
95 or GT depending on payer02•  Audio & Video•  Schedule your patients as you normally would
•  At the time of the televisit, your MA and patient can log into telemedicine platform
– Make sure you have a statement that indicates the service was performed via Telehealth at the beginning of your progress note
– Indicate the location of the patient, i.e. at home
– Make sure to notify the patient that third-party telemedicine platforms may have privacy risk
•  Document in your EHR as usual for office visit, except the Physical Exam (PE)
•  PE need not be in person if the telemedicine encounter is sufficient to establish an informed diagnosis
•  Provider may want to consider documenting the detailed assessment and plan based on complexity of the disease
– Indicate the time spent with the patient
•  Follow the same clinical guidelines you would with an in-person visit
Virtual
Check-in
•  G2012 (5-10 minute medical discussion on the phone)
•  G2010 (Remote evaluation of recorded video/image)
Check payer rules12•  Audio, or
•  Audio & Video, or
•  Image
•  Applicable to established patient who initiates a communication
•  Patient must verbally consent to services and should be informed that the Medicare coinsurance and deductible will apply
•  Not related to a visit in the past 7 days and does not lead to a medical visit in the next 24 hours
E-Visit• 99421 – 99423 (Physicians)
• G2061 – G2063 (Qualified non-Physicians)
Check payer rules12•  Online Portal•  Applicable to established patient who initiates communication
•  Patient must verbally consent to services and should be informed that the Medicare coinsurance and deductible will apply
•  Patient communicates with provider without going to the providers office by using online patient portal
•  The communications can occur over a 7-day period

*Notes: 

1To the extent the 1135 waiver requires an established relationship, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency.  For more information on establishing patient-provider relationship please refer to website here.

2Documentation requirements for any form of virtual care (telehealth or non-telehealth online service) are the same as those for documenting in-person care.  For time-based coding, evidence of time must be documented.  If exchanged asynchronously, images, videos and communications must be stored and retained according to state regulations.  Real-time and interactive video visit, or a video-phone call visit are not required to be stored.

3For FQHC’s or RHC’s, the geographic and site restrictions still apply.  In other words, the FQHC’s and RHC’s can serve as the originating site for telehealth services, however the patient has to be present at the site and not their home.  Evaluation or discussion is not related to a visit in the past 7 days and does not lead to a medical visit in the next 24 hours.  Both FQHC’s and RHC’s need to use HCPCS code “G0071” with modifier “GT”.

As it relates to e-prescribing for controlled substances, while COVID-19 public health emergency remains in effect, DEA-registered providers may issue prescriptions for controlled substances to patients for whom they have not conducted an in-person medical evaluation, provided all of the following conditions are met:

  • The prescription is issued for a legitimate medical purpose by a provider acting in the usual course of his/her professional practice
  • The telemedicine communication is conducted using an audio-visual, real-time, two-way interactive communication system
  • The provider is acting in accordance with applicable federal and state laws

Disclaimer:

This information is provided as a tool to help you understand the latest changes in telemedicine billing as a result of COVID-19 emergency. TriumpHealth employees and staff have created this presentation to the best of their knowledge and ability, and make no representation or guarantee that this presentation is error-free. TriumpHealth has no liability or responsibility to any person or entity with respect to any loss of revenue, or indirect damages resulting from the potential use of this information.

by Tej Gill, VP – Healthcare Solutions | TriumpHealth