Practicing Telemedicine during the Pandemic

In these quickly changing times we’re turning to trusted colleagues and reliable sources for information to help your practice and patients.

Here is a link to telemedicine pointers from MSMS: https://www.msms.org/About-MSMS/News-Media/telemedicine-can-help-social-distancing-efforts

Thanks to the societies in Minnesota and Wisconsin for sharing the following.

First is a good summary. Second, is more detailed coding information developed by the Pennsylvania Academy of Ophthalmology. We share it in the hope that you will find it useful as you implement remote care for your patients.

Note:  Carriers update their policies frequently. Please check back for new and additional information.

There are three options for telehealth and other communications-based technology services.

  1. Telephone Calls
Code Value Description
HCPCS code G2012 $14.81

Medicare Part B.

Coverage varies per commercial plan

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

Used for an established patient who calls and speaks to an ophthalmologist or optometrist. A decision might be made to prescribe warm compresses for a chalazion, counsel about blepharitis, refill a prescription etc. It can only be billed if it does not relate to a visit in the past 7 days and does not lead to a visit within 24 hours. Documentation requirements as below.

* Documentation Requirements for HCPCS code G2012

  • Confirm patient identity (e.g., name, date of birth or other identifying information as needed, in particular if documenting independently from the patient’s electronic or paper record).
  • Confirm that the patient is an established patient to the practice
    • Detail what occurred during the communication (e.g., patient problem(s), details of the encounter as warranted) to establish medical necessity
    • Document the total amount of time spent in communicating with the patient and only submit code G2012 if a minimum of five minutes of direct communication with the patient was achieved
  • Document that the nature of the call was not tied to a face-to-face office visit or procedure that occurred within the past seven days
  • Document that a subsequent office visit for the patient’s problems were not indicated within 24 hours or the next available appointment
  • Include that the patient provided consent for the service

Verbal consent of the patient must be documented

Phone calls with MDs, DOs, ODs

Code Value Description
99441 Non-covered Medicare services.

Coverage varies per commercial plan

Telephone evaluation and management service by a physician may report E/M services provided to an established patient, parent, or guardian 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
99442 11-20 minutes of medical discussion
99443 21-30 minutes of medical discussion

Please note that above codes are not covered by Medicare but may be covered by Private plans. Instead, use G2012 to report a telephone call with a physician or optometrist of 5-10 minutes

Phone calls with PAs or NPs

Code Value Description
98966 Non-covered Medicare services.

Coverage varies per commercial plan

Telephone assessment and management service provided by a qualified nonphysician, heath care professional to an established patient, parent, or management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion
98967 11-20 minutes of medical discussion
98968 21-30 minutes of medical discussion
  • Initiated by established patients
  • If the telephone service ends with a decision to see the patient within 24 hours or the next available urgent visit appoint, the code is not reported; rather the encounter is considered part of the preservice work of the subsequent assessment and management service, procedure and visit.
  • Likewise, if the call refers to a service performed and reported within the previous seven days or within the postoperative period of the previous completed procedure, then the service is considered part of the previous service or procedure.
  1. Internet Consultations
  • Initiated by established patients
  • Covers 7 days
  • Not to be used for
    • Scheduling appointments
    • Conveying test results
  • Must be through HIPAA compliant secure platforms such as
    • EHR portals
    • Secure email, etc.

Internet Consultations with Physicians

New codes in 2020

Code Value Description
99421 $15.52 Online digital E/M service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 min
99422 $31.04 11-20 minutes
99423 $50.16 21 or more minutes

Initiated by the patient. Internet based (secure email or portal) This is entirely based on time spent with patient which should be documented. AdviseDocumentation Requirements for HCPCS code G2012 as in G2012 code.

Internet Consultations with Non- Physicians such as Physician Assistants and Nurse Practitioners

New codes in 2020

Codes Value Description
98970 $0 Online digital E/M service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 min
98971 $0 11-20 minutes
98972 $0 21 or more minutes

Not covered by Medicare but may be covered by private payers

  1. Telemedicine Exams
  • Telemedicine Exams
    • Telemedicine is defined by a real-time interaction between a physician or other qualified healthcare professional and a patient who is located at a distant site from the physician.
    • The examination and communication of information exchange between the physician and the patient must be the same as when rendered face-to-face.
    • Code level selection is based on same criteria for the base codes
    • Telemedicine codes are identified by a star (*) in your CPT book
      • Office based
    • 99201 – 99205 E/M new patient
    • 99212 – 99215 E/M established patient
    • Does not apply to tech code 99211 or Eye visit codes
      • Office consultations
  • For insurances that still recognize this family of codes
    • 99241 – 99245
      • Subsequent Hospital Care
    • 99231 – 99233
      • Inpatient Consultation
    • 99251 – 99255
      • Subsequent Nursing Facility Care
    • 99307-99310
    • Append modifier -95 Synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications systems.

Guidance from Independence Blue Cross: Professional providers performing telemedicine services must report the appropriate modifier (Modifier GT or 95) and place-of-service (POS) code 02 (Telehealth) to ensure payment of eligible telemedicine services.

Typically these codes are allowed only in counties outside a Metropolitan Statistical Area (MSA) or in a rural Health Professional Shortage Area (HPSA) in a rural census tract. We have been told that CMS plans to waive these requirements during the COVID-19 Pandemic. This was just announced by President Trump, and notification is felt to be imminent.

https://data.hrsa.gov/tools/shortage-area/hpsa-find

These visits require the same documentation as for in office E&M visits. These visits should document the same information as your EHR or paper templates that you are currently using. It is assumed technicians could be used remotely similarly to how they are utilized in the office, but there is no guidance on this.

Per CMS “You must use an interactive audio and video telecommunication system that permits real-time communication between you at the distant site and the beneficiary at the originating site” Transmitting information that is reviewed later is not allowed.

Source: https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet 

These codes for consultative service requested by another provider were not covered in the AAO document above:

Reimbursement for Inter-professional Internet Consultation

CPT Codes 99446-99449, 99451, and 99452

Assessment and Management codes conducted through telephone, internet, or electronic health record consultations furnished when a patient’s treating physician or other qualified healthcare professional requests the opinion and/or treatment advice of a consulting physician with specific specialty expertise to assist with the diagnosis and/or management of the patient’s problem without the need for the patient’s face-to-face contact with the consulting physician or qualified healthcare professional.

CPT 99446: Interprofessional telephone/Internet electronic health record assessment and management service provided by a consultative physician including a verbal and writtenreport to the patient’s treating/requesting physician or other qualified health care professional; 5-10 minutesof medical consultative discussion and review

CPT 99447: Same as 99446, but 11-20 minutes of medical consultative discussion and review

CPT 99448: Same as 99446, but 21-30 minutes of medical consultative discussion and review

CPT 99449: Same as 99446, but 31 minutes or more of medical consultative discussion and review

The codes above require a consultation from another qualified provider and both written and oral report

CPT 99451: Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician including a written report to the patient’s treating/requesting physician or other qualified health care professional, 5 or more minutes of medical consultative time

CPT 99541 requires a consultation from another qualified provider but only a written report

CPT 99452: Interprofessional telephone/Internet/electronic health record referral service(s) provided by a treating/requesting physician or qualified health care professional, 30 minutes (Note this is for the consulting physician to bill)

Please note that verbal consent must be documented in the patient’s chart for all of these codes

HCPCS Code G2010 Remote Evaluation of Images

HCPCS 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.