COVID- 19: Telehealth Services

Telehealth Services
March 17, 2020

There are three types of Telehealth:
1. E-Visits – On-line portal, e-mail text questions, etc.
2. Virtual Check-In – Telephone calls, patient e-mail pictures, etc.
3. Telehealth Visits – Two-way audio/visual (skype, facetime, etc.).

Background
On March 13, 2020, the president announced an emergency declaration under the Stafford Act and the National Emergencies Act. Consistent with the president’s emergency declaration, CMS is expanding Medicare’s telehealth benefits under the 1135 waiver authority and the Coronavirus Preparedness and Response Supplemental Appropriations Act.
As part of this announcement, patients will now be able to access their doctors using a wider range of communication tools including telephones that have audio and video capabilities, making it easier for beneficiaries and doctors to connect.

Clinicians can bill immediately for dates of service starting March 6, 2020. Telehealth services are paid under the Physician Fee Schedule at the same amount as in-person services. Medicare coinsurance and deductible still apply for these services. Additionally, the HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.

To read the Fact Sheet on this announcement visit: https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet.

To read the Frequently Asked Questions on this announcement visit: https://www.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf.

E-visits
Established patients initiate non-face-to-face communications with their doctors by using online patient portals. Patient initiates and gives verbal consents to this service. Providers may educate patients on the availability of these services. E-visits are billed based on time spent over a 7 days period. There aren’t any geographical restrictions; meaning does not have to be rural setting.

Physicians and nurse practitioners may bill the following codes:
99421: Online digital E&M service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes
99422 … 11-20 minutes
99423 …21 or more minutes

Clinicians who are not able to bill E&M Services, such as physical therapists, occupational therapists, speech language pathologists, and clinical psychologists the following codes are available to them:
G2061: Qualified non-physician healthcare professional online assessment and management, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes
G2062: …11-20 minutes
G2063: …21 or more minutes

Virtual check-ins
Established patients may have brief communication with their provider over the telephone OR exchange information through video or image. CMS expects that this will be initiated by the patient, but offices can educate patients to the availability of this service. Patients must give a verbal consent for this service. It is our understanding that this could be provided via telephone (without visual component), email, text messaging or patient portal messaging.

Codes: G2012 Brief communication technology-based services, 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 with the previous 7 days no leading to an E&M service or procedures within the next 24 hours or soonest available appointment: 5-10 minutes of medical discussion.
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 or procedure within the next 24 hours or soonest available appointment.

Telehealth Visits
Patients and providers use an interactive audio video telecommunication system that permits real-time communication. This is for a visit, which normally takes place face-to-face. Providers will be reimbursed the same as a face-to-face visit. Patients may be in their homes. HIPAA requirements have been eased, with the expectation that providers will still be mindful of the sensitive information of their patients. CMS is allowing the use of any type of audio-visual real-time technology (Skype, FaceTime, etc.). Deductible and co-insurance applies to these services, the Office of Inspector General is allowing some flexibility, providers may waive or reduce the patient’s out-of-pocket liability during this time.

Types of providers: physicians, nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologists, clinical social workers, registered dieticians, and nutrition professionals.

Summary

There are three types of Telehealth: E-visits, Virtual Check-in, and Telehealth Visits.  Listed below are the three types of Telehealth available, and the associated CPT codes.

Below is a link to the complete list of procedures codes.

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