The following Q & A is a follow up to a webinar on this topic. If you’d like to view the webinar go to COVID-19 & Telehealth Related Coding Guideline Webinar
|Q: Is the modifier 95 and standard POS for all the telehealth codes, plus the most recent update of 80 codes or ONLY for the new 80 codes?
A: CMS has indicated that the 95 modifier be used for telehealth service provided which would have been provided as a face-to-face service otherwise. This applies to office services and facility consult services. Here is a list from the March 30, 2020 CMS fact sheet which lists all the services eligible for reimbursement with a modifier 95; remember, the place of service in which the service would normally have been furnished should still be reported. In this way, CMS may reimburse the service as it would normally have been reimbursed rather than at a reduced telehealth rate.
• Emergency Department Visits, Levels 1-5 (CPT codes 99281-99285)
For more information, follow this link: https://www.cms.gov/files/document/covid-19-physicians-and-practitioners.pdf
Q: We run into telehealth concerns as we cross state lines due to the legal aspects of independent state licensure. Beyond COVID-19, do you know if there are proactive actions happening behind the scenes to increase functionality with regard to state guidelines?
A: Regarding state licensure and how payers approach eligibility for reimbursement, your approach should ultimately remain the same. CMS has published its relaxed guidelines relating to provider eligibility for reporting and reimbursement. We encourage you to remain vigilant in ensuring that you are up to date with any local payer reporting and reimbursement changes. This could include government payers such as Tricare and Medicaid, but also commercial payers such as Blue Plans, Aetna, CIGNA, UHC, and any large self-funded third-party payers.
|Q: Can Residents at Teaching facilities perform Virtual Visits and/or Telehealth, without direct involvement from the Attending provider?
A: With regard to attending supervision of residents, CMS states the following “Teaching physicians can provide services with medical residents virtually through audio/video real-time communications technology. This does not apply in the case of surgical, high risk, interventional, or other complex procedures, services performed through an endoscope, and anesthesia services. This allows teaching hospitals to maximize their workforce to safely take care of patients.” This may be found at the following link: https://www.cms.gov/files/document/covid-teaching-hospitals.pdf
|Q: Is the provider required to document if video was not available to bill the Telehealth code since the video portion was waived?
A: In order to support reporting for reimbursement purposes, all services provided should be documented, regardless of the method in which the service was provided. Different services have differing documentation requirements. In short, telehealth services are real-time audio and video services. These are distinctly different from a service which is real-time audio only. To our knowledge, CMS has not stated that real-time audio-only services may be reported as telehealth services.
To clarify: For reporting purposes, CMS requires telemedicine services to be real-time, two-way (bi-directional) audio plus visual encounters. If the visual portion is only one-way, or if the encounter is audio only, it is appropriate to report as a telephone service, which CMS has stated it will cover during the pandemic.
|Q: To bill a new patient visit, are the components based on time or MDM?
A: On an interim basis, CMS has revised its policy to specify that the office/outpatient E/M level selection for the services when furnished via telehealth can be based on MDM or time, with time defined as all of the time associated with the E/M on the day of the encounter; and to remove any