The RT Welter team is closely monitoring the payer updates for telehealth as they continue to unfold. Please do not hesitate to contact us if you have any coding or billing issues. Ginger Avery, CPC, CPMA, CRC, is the Coding and Compliance Manager at RT Welter & Associates, Inc. Below, she provides information regarding important payer Telehealth updates for Colorado. Read below for these important updates and whether other important information is fact or fiction.
Center for Connected Health Policy CCHP State Laws & Reimbursement Policies Updated 04/03/2020
Telehealth refers broadly to electronic and telecommunications technologies and services used to provide care and services at-a-distance.
Telemedicine is the practice of medicine using technology to deliver care at a distance. A physician in one location uses a telecommunications infrastructure to deliver care to a patient at a distant site.
Telehealth is different from telemedicine in that it refers to a broader scope of remote health care services than telemedicine. Telemedicine refers specifically to remote clinical services, while telehealth can refer to remote non-clinical services.
PHE = Public Health Emergency
Asynchronous = “store-and-forward video-conferencing,” which is the “transmission of recorded health history to a health practitioner. Asynchronous telemedicine involves acquiring medical data, then transmitting this data to a doctor or medical specialist at a convenient time for assessment offline.
Synchronous = “live video-conferencing,” which is a two-way audiovisual link between a patient and a care provider. Synchronous telemedicine requires the presence of both parties at the same time and a communication link between them that allows a real-time interaction to take place.
Office or other outpatient visits (Telehealth)
99201 – 99215 Office or other outpatient visits for the evaluation and management of a new (or established) patient.
Fact: Place of Service (POS) should be “02” telehealth.
Fact: Must be MD, DO or mid-level (aside from 99201/99211).
Fiction: You can charge New Patient visits codes for Established Patient visits.
Emergency Department or Initial Inpatient Services (Telehealth)
G0425 – G0427 Telehealth consultation, emergency department or initial inpatient, typically XX minutes communicating with the patient via telehealth, depending on the severity/acuity of the patient (problem-focused, detailed or comprehensive).
These codes are used to report an initial inpatient or emergency department consultative visit or consultations that are furnished via telehealth in response to a request by the attending physician. Place of service should indicate the location at which patient resides, eg; 21 Inpatient or 23 Emergency Department
G0406 – G0408 Follow-up inpatient consultation, limited, physicians typically spend XX minutes communicating with the patient via telehealth
These codes are used to report consultative visits or consultations that are furnished via telehealth in response to a request by the attending physician to follow up on an initial consultation or a subsequent consultative visit. Place of service should indicate the location at which the patient resides, eg; 21 Inpatient
Fact: Must be MD, DO or mid-level.
Fact: Consultations must provide evidence that a request for service from attending was conducted as well as plan/treatment recommendation were communicated back to requesting clinician.
Virtual Check-In (Telemedicine)
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
Physicians or other qualified practitioners review photos or video information submitted by the patient to determine if a visit is required. For asynchronous transmissions (e.g., store and forward), Place of Service should be indicated as ’11’ office.
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
*A brief (5-10 minutes) check-in with clinician via telephone or other telecommunications device. A physician or other qualified health care professional conducts a virtual check-in, lasting five to 10 minutes, for an established patient using a telephone or other telecommunication device to determine whether an office visit or other service is needed. Place of service should indicate whether visit was conducted via telephone ’02’ telehealth or other telecommunications device ’11’ office.
Fact: For established patients only.
Fact: Must be MD, DO or mid-level.
Fact: Communication is not related to a medical visit within the previous 7 days and does not lead to a medical visit within the next 24 hours.
Fact: Patient consent needs obtained to receive virtual check-in services.
E-Visits (Telemedicine) A communication between a patient and their provider through an online patient portal.
99421 – 99423 Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; XX minutes
These codes are used to report non-face-to-face patient services initiated by an established patient via an on-line inquiry (eg. secure email, EHR portal, or other digital application). Providers must provide a timely response to the inquiry and the encounter must be stored permanently to report this service. Place of Service should be indicated as ’11’ for this asynchronous service.
Fact: Medicare Fee Schedule indicates Colorado reimbursement rates from $15.52 – $50.16 for these services.
G2061 – G2063 Qualified non-physician health care professional online assessment, for an established patient, for up to 7 days, cumulative time during the 7 days; XX minutes
These codes represent patient-initiated, digital communications that require a clinical decision that typically otherwise would have been provided in the office. Clinicians who may not independently bill for evaluation and management visits (for example – physical therapists, occupational therapists, speech language pathologists, clinical psychologists) should use G2061-G2063. Place of Service should be indicated as ’11’ for this asynchronous service.
Fact: Medicare Fee Schedule indicates Colorado reimbursement rates from $12.27 – $33.92 for these services.
Fact: Patient initiates communication through an EHR portal, secure email or other digital application.
Fact: Patient consent should be obtained to receive virtual check-in services.
Fact: For established patients only.
Once an 1135 Waiver is authorized, health care providers can submit requests to operate under that authority or for other relief that may be possible outside the authority to the CMS Regional Office with a copy to the State Survey Agency. Request can be made by sending an email to the CMS Regional Office in their service area. Contact information to Request to Operate Under 1135 Waiver
1135 Waiver Facts: 1135-Waiver Info Here
- Consents are required. Stored recordings of verbal consent are recommended, however, written documentation supporting the services reported should clearly indicate the patients consent to treat.
- HHS will NOT penalize clinicians for waiving copays/out of pocket (OOP). Clinicians are encouraged by Medicare to waive patients OOP, although this is not an official requirement. OIG OFFICIAL DOCUMENT
- Waiver can be for any emergent or acute problem, not just COVID19. Acuity/urgency must be evident in documentation.
- Waiver is not for routine check-ups or non-urgent encounters. Ethical standards apply.
- The originating site requirements are waived. Clinicians and patients can communicate in their home settings.
- Providers are expected to come into compliance with any waived requirements prior to the end of the emergency period.
- CMS has approved specific waivers & modifications only to the extent that the provider in question has been affected by the disaster or emergency.
- Waivers or modifications under section 1135 of the SSA may be retroactive to the beginning of the emergency period (or to any subsequent date).
- The waiver or modification terminates either upon termination of the emergency period or 60 days after the waiver or modification is first published (subject to 60-day renewal periods until termination of the emergency).
- Visits are considered the same as in-person visits and are paid at the same rate as regular, in-person visits.
- To 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. This is not intended to allow billing for new office visits for established patients.
Other Take Homes:
- All services should be documented/recorded and stored in the EHR to support medical necessity.
- Services must support actual code descriptions. Document what you do, code what you document.
- Check with your current payers to verify specific telehealth/telemedicine requirements.
- Consider researching various intake platforms that will help assist with service communications/ requirements.
- Video & phone calls must be saved by recorded or written documentation in the EHR.
- None of the listed services in this article are billable by clinical staff.
- Time spent with the patient should be documented in all encounters.
- HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (HIPAA): Effective immediately, 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.