To further mitigate the spread of COVID-19 while minimizing exposure for patients, CMS has temporarily relaxed the telehealth requirements. Specifically, CMS has waived certain telehealth restrictions, as well as reduced the financial constraints for beneficiaries, during the Public Health Emergency.
Below, we highlight guidance for virtual, e-visit and telehealth non face-to-face encounters to assist physicians and healthcare practitioners navigate these unprecedented times. In addition, we provide the temporary diagnosis code for COVID-19 along with the applicable HCPCS codes for laboratory services.
Virtual Visits
Described as a brief, non-face-to-face communication initiated by a patient to their healthcare provider, a “virtual check-in” is a payable service under the Medicare Physician Fee Schedule (“MPFS”), allowing a beneficiary to remain in his/her home while accessing care. Unlike telehealth visits, virtual check-ins can be conducted with a broader range of communication methods and don’t require a video interaction, which can be particularly helpful in determining whether or not an office visit or other service is warranted. Virtual check-ins are separately billable stand-alone services reported with the following HCPCS codes:
G2012 - Patient “checks in” with a practitioner via telephone or other telecommunication device to determine whether an office visit or other service is needed. This is a real-time service generally involving 5 – 10 minutes of medical discussion between a physician or other qualified non physician practitioner.
G2010 - A practitioner reviews patient-transmitted photos or video to assess whether a visit is needed. This service requires a response from the physician for remote evaluation of recorded video and/or images submitted by the patient. Follow-up with the patient can take place via phone call, audio/video communication, secure text messaging, email or patient portal communication.
Important tips related to virtual check-in visits:
Established patients only
Rendered by physician/qualified healthcare professional who can report E&M services
Must be initiated by patient
Verbal or written consent noted in the medical record for each service
Beneficiary cost-sharing applies (deductible and co-insurance)
Not originating from a related E&M provided within the previous 7 day
Not separately reported if the encounter leads to an appointment within 24 hours (or soonest available
E-Visits
The 2020 MPFS authorized payment for additional non-face-to-face encounters involving online communication between a physician or non-physician practitioner and an established patient. In contrast to a virtual visit, these six (6) codes require a clinical decision that would otherwise be provided in the office, utilizing online patient portals over a 7-day period. The code set, identified below, distinguishes between the work of physicians and nonphysician practitioners.
E-visits between an established patient and a physician may be reported using the following CPT codes:
99421 (Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes)
99422 (Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 11-20 minutes)
99423 (Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 21 or more minutes)
E- visits between an established patient and non-physician practitioner may be reported using the following HCPCS codes:
G2061 (Qualified nonphysician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days;5-10 minutes)
G2062 (Qualified nonphysician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 11-20 minutes)
G2063 (Qualified nonphysician healthcare professional assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 21 or more minutes)
Telehealth - Expansion With 1135 Waiver
Effective March 6, 2020, and for the duration of the COVID-19 Public Health Emergency, prior site restrictions have been waived making it easier for beneficiaries and doctors to connect, avoiding travel to physicians’ offices, clinics, hospitals, or other healthcare facilities. During this temporary period, providers are also permitted to reduce patient cost-sharing for telehealth services.
Facilitating access to E&M services while minimizing patient exposure, the originating site requirement has been relaxed so that patients can remain in their homes to receive healthcare services. To render care via telehealth, however, the provider must use an interactive audio and video telecommunications system that permits real-time communication between the distant site and the patient at home. Considerations for reporting telehealth during the COVID-19 Public Health Emergency:
Previous originating site requirements have been waived and Medicare will make payment for telehealth services furnished to beneficiaries in any healthcare facility, or patient’s residence, in all areas of the country
Telehealth services may be provided to Medicare beneficiaries via telephone only if the phone allows for both audio and video interaction between the provider and the patient. Use of “Smart Phones” is permitted predicated the device supports the two-way, real-time interaction.
The Office of Civil Rights (“OCR”) will temporarily exercise enforcement discretion and waive penalties for HIPAA violations against healthcare providers serving patients in good faith through technologies such as FaceTime or Skype.
Subject to state law, practitioners who can furnish and get payment for covered telehealth services may include physicians, nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologists, clinical social workers, registered dietitians and nutrition professionals.
Visits rendered via telehealth are considered the same as in-person visits and are paid at the same rate as regular, in-person visits.
Coinsurance and deductible apply; however, during the COVID-19 Public Emergency Period, HHS is providing flexibility for providers to reduce or waive cost-sharing for telehealth services.
Telehealth encounters, unlike virtual check-ins and e-visits, can be reported for new patients.
While the 1135 waiver requires an established relationship between beneficiary and provider, i.e. a service paid to the practitioner or practice during the preceding three (3) year period, HHS has made clear it will not conduct audits to ensure a prior relationship existed for claims submitted during this public health emergency.
Telehealth services should be reported using Place of Service (“POS”) code 02.
A wide range of services, including preventive and counseling services, may be rendered via telehealth. A complete list of Medicare approved telehealth services can be found at:
https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes
Diagnosis and HCPCS Codes
A temporary ICD-10 diagnosis code U07.1 was developed for reporting COVID-19 with a new diagnosis code to be developed/implemented with the yearly updates in October of 2020.
Two new lab HCPCS codes that the Medicare claims processing system will be able to accept as of April 1, 2020, for dates of service on or after February 4, 2020:
U0001 - Coronavirus Real Time RT-PCR Diagnostic Test Panel. This code will allow those laboratories conducting the tests to bill for the specific test instead of using an unspecified code.
U0002 - Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19) using any technique, multiple types or subtypes (includes all targets).
SunStone offers services specifically geared to assisting hospital based and independent multi-specialty physician groups manage the ever-changing professional regulatory environment. If you have any questions, please contact Vonda Moon, Senior Principal at vondamoon@sunstoneconsulting.com or Joli Fitzgibbons, Senior Manager at jolifitzgibbons@sunstoneconsulting.com.