In March, the Centers for Medicare & Medicaid Services (CMS) signed Waiver 1135, which brought on significant changes to telemedicine service qualifications, and billing and coding procedures, while the nation battles the novel coronavirus disease (COVID-19).
Some insurance companies are following CMS’ lead, but each has its own unique policies. Jill Young, CPC, CEDC, discussed these changes and reviewed what codes are now available for Medicare telehealth/telemedicine services in an April 9 AOA/AOIA webinar. View the webinar slides here.
A lot—an overview is below. Also, CMS’ new policies are outlined in detail here.
CMS added 80 new telemedicine codes for use during the extent of this public health emergency (PHE), backdated to March 1.
How does telehealth eligibility look different during COVID-19?
Previously, physicians had to consider a patient’s location when coding for telemedicine under Medicare. During this PHE, the 1135 waiver has relaxed restrictions on originating sites, so patients can be in their homes or virtually anywhere within reasonable range of their physician.
There have been no changes regarding which providers are eligible to provide services. However, Medicare has a fast track application process. The possibility an applicant would be approved for temporary billing privileges during a call to CMS exists. Typical credentialing information is collected on the call with the waiving of several of the normal screening requirements.
How do these changes impact billing & coding procedures?
Place of service (POS) & modifiers: For all Medicare services backdated to March 1, instead of billing POS 02, as one normally would for telemedicine visits, bill the place of service where your provider would usually provide that code and service under normal circumstances.
For instance, if a service would have normally been provided in your office, POS 11, that’s what you should bill. To indicate that the service was done using telecommunication technology, use Modifier 95.
If you bill POS 02 for Medicare telehealth visits, it will automatically reduce your pay. If you have done this already, you can complete a clerical error reopening using the online topic or appeals section of your MAC website to get the correct payment.
Medicare says that if only audio, and not video, are possible for a telehealth visit, these code rules do not apply. The service would be a telephone call and newly payable by the Medicare codes 99441-99443. But on CMS calls, the possibility of additional changes to code requirements has been mentioned, without further detail or timelines. Other insurers have been more flexible, but physicians should research them individually.
Documentation: Providers can still use the documentation guidelines (1995 or 1997) they currently use. Additionally, they may use the concept of MDM (medical decision making) alone or Total Time from the 2021 anticipated guidelines that have been approved for this PHE.
The Total Time concept from 2021 is provider time only in selecting a level of service, from the time they sit down with the chart or open a record. For the MDM concept of selecting a level of service, a clinically appropriate history and exam are still taken, but the documentation for those elements is not required.
When deciding what order to put multiple modifiers in on a claim, the order is payment modifiers first, and informational second.
New COVID-19 code
The new confirmed COVID-19 diagnosis code, effective April 1, is: U07.1 – COVID-19.
Find guidelines on how to use this code on the CDC website. Quick relevant details:
- Code only confirmed cases: a positive test result, or a presumptive positive test result.
- Always sequence it first (except during pregnancy, child birth and the puerperium where codes from Chapter 15 always take sequencing priority), then follow it with appropriate codes for associated manifestations.
- In the absence of a confirmed diagnosis, use the signs and symptoms the patient had for your diagnosis.
Other relevant changes during the PHE
HHS and OCR relax restrictions: Typically, patients are only eligible for telehealth services if they have a prior established relationship with a provider. But HHS is saying it will not conduct audits on that for now. Effectively, this allows providers to see new Medicare patients virtually. Old frequency restrictions for telehealth visits have also been waived.
Additionally, the U.S. Office for Civil Rights has recently waived penalties for violating certain HIPAA Security and Privacy regulations through COVID-19. To learn more about that, please see the summary of the AOIA’s April 6 webinar, Navigating HIPAA and Telemedicine.
Patient consent: Medicare doesn’t require it prior to a telehealth service taking place, but it is required for certain parts of the service, like a virtual check-in. Young suggests having staff get consent every time and entering it into the record to be safe. Consent can be written or verbal.
Additionally, patients must initiate contact with providers. Physicians can call and let patients know they are offering telehealth services if a patient has contacted them about an issue, but “cold calls” are prohibited.
Patient financial liability: Typically, telehealth does not change the out-of-pocket costs for patients under Medicare, which means they are liable for copayments and coinsurance. Providers may now reduce or waive cost-sharing for telehealth visits paid for by federal health care programs. Young has advice for making sure you don’t lose out on fees you are owed at 21:39 in the video above.
Deductibles: Until further notice, HHS is not penalizing health insurers that amend catastrophic plans to waive copays and deductibles for COVID-19-related services.
Many insurers are still figuring this out. Aetna, as an example, is not requiring patients to pay copays for telemedicine visits from March 6-June 4, and instructs coders to use either GT or 95 modifiers. Research individual payers to see what their policies are and note that they may change.
Licensure: Physicians who are licensed in their home state can now see patients in other states under Medicare. Each state may still have other restrictions that need to be addressed. Be sure to check with your malpractice carrier before providing telehealth services in any state, including your own, to make sure you have the correct coverage.
Center for Connected Health Policy
National Consortium of Telehealth Resource Centers
CMS Current Emergency Website