In response to the COVID-19 pandemic, CMS made several policy changes that allowed Medicare beneficiaries to access a wider range of telehealth services, alleviating some of the burden and risk of an in-person encounter at a healthcare facility. This coverage was established due to the public health emergency (PHE) for COVID-19.
The coverage began on March 6, 2020, and remains in effect throughout the PHE. The PHE guidelines indicate that special coverage determinations have a limit of 90 days and then must be re-evaluated and either extended or termed at the end of the 90-day period. As of July 20, 2021, the PHE, and coverage for telehealth services has been extended for another 90 days through October 18, 2021.
Unfortunately, many practices have misinterpreted the PHE Telehealth guidelines and have been billing for “audio-only” services as if they were face-to-face office visits. These practices may now find themselves under scrutiny from the Office of Inspector General (OIG). The “audio-only” communication technology-based services (CTBS) are now on the OIG’s 2021 Work Plan. Medical practices should review and self-audit these services to ensure they can pass a formal audit.
Audio-only Communication Requirements
With the confusion around the changes to telehealth coverage during the COVID-19 PHE, CMS has received several questions. The following Question and Answer was posted on the CMS FAQ in April 2020 and again in September 2020.
QUESTION: What are the requirements to use regular office visit codes (i.e., new patient codes 99201–99205 and established patient codes 99212–99215) with telehealth? Can regular office visit codes be used for just a phone call between the provider and the patient, that does not include video capability?
ANSWER: No. The provider must use a telecommunication application, which mandates audio AND video, under Waiver 1135. The CPT® codes for these services are 99441–99443. Again, these codes are for temporary use during the PHE as CMS does not (and will not continue to) reimburse for phone calls when there is no PHE.
CMS added audio-only phone calls to the telehealth list which requires appending modifier 95 Synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system for any approved telehealth services. However, this only applies for the duration of the COVID-19 PHE. This extended benefit may change once the PHE has ended.
Phone Call Codes 99441-99443
- These phone call CPT codes range from 99441-99443 and are all based on time. These are non-face-to-face E&M services and are only to be reported by a physician or other qualified healthcare professional (e.g. NP or PA).
- During the PHE, these phone call codes are another means for a patient to communicate with their clinician, when they don’t have access to audio and video communication technology for their encounter.
- The phone call code requirements include documentation of total time, be initiated by the patient, and are for established patients. However, the last requirement has been relaxed during the COVID-19 PHE, for the duration of the PHE, CMS will temporarily allow these encounters to be used for New and Established patients.
- Remember – Do Not Use these codes if the service ended with a decision to see the patient within the next 24 hours, or “next available appointment”. However, the work and documentation during this service is considered “pre-work” for the subsequent scheduled visit. Ensure that your clinicians are pulling this into the documentation for the subsequent encounter, so the appropriate level of service is calculated.
- These services also have a 7-day global period. This means you can’t code and bill for a phone call if the same provider has seen the patient for the same problem in the previous 7 days.
Virtual Check-In Codes G2250, G2251 and G2252
- These virtual check-in codes are for brief audio-only and recorded video and/or images sent in by an established patient, not a two-way audio-video communication directly with a clinician.
- G2250 is for a remote evaluation of a recorded video and/or images submitted by the patient (e.g store and forward). This includes interpretation and follow-up with the patient by a physician or qualified healthcare professional within 24 business hours. This is NOT a time-based code
- G2251 and G2252
- These are both brief CTBS, virtual check-in encounters with the patient by a physician or other qualified healthcare professional, that does not originate from a related E&M service provided within the previous 7 days, nor does it lead to an E&M service or procedure within the next 24 hours or soonest available appointment.
- These are time-based codes – Don’t forget to document the time!
- G2251 is for 5-10 minutes of medical discussion.
- G2252 is for 11-20 minutes of medical discussion.
In conclusion, ensure that you’re documenting your virtual CTBS encounters appropriately. If you’re using two-way audio and visual form of CTBS, the documentation must clearly state and support this in order to bill these services with one of the face-to-face E&M service codes (e.g. 99201-99215) during the COVID-19 PHE.
However, if the service is just a phone call or other virtual check-in form of CTBS, then the documentation should support that and include the time when required. Bill these services using one of the above code choices as appropriate.