ACE Alert – Clarification on Telephone Only Visits April 2, 2020

As we continue to receive updates and changes regarding coding and billing for Telehealth and Telemedicine services, it’s important to slow down and evaluate what has or has not changed with each new instruction.  Be sure you are relying on information from CMS.

The latest change from CMS on March 30, 2020 addresses coding for telemedicine services provided to patients who have audio phones only with no video capability.

A Telemedicine check-in visit via phone or video call is still to be billed with specific codes G2012 to Medicare and 99441 – 99443 for non-Medicare as POS 11.  You are also to append the 95 modifier to show that this is during the crisis period.  This is intended to be used for both new and established patients.

The CMS update specifically states: “However, in the context of the goal of reducing exposure risks associated with the PHE for the COVID-19 pandemic, especially in the case that two-way, audio and video technology required to furnish a Medicare telehealth service might not be available, we believe there are many circumstances where prolonged, audio-only communication between the practitioner and the patient could be clinically appropriate, yet not fully replace a face to face visit.  We believe that the existing telephone E/M codes, in both description and valuation, are the best way to recognize the relative resource costs of these kinds of services.  Therefore, we are finalizing, on an interim basis for the duration of the PHE for COVID-19 pandemic, separate payment for CPT codes 99441-99443.”

For the Telehealth Services, it does require both audio and video during the visit.  You are to bill with the evaluation and management services, 99201-99215, with place of service 11 or 22 depending on your situation.  Then you must append the 95 modifier to indicate telehealth during the crisis period.

Both exceptions will go away once the crisis has been lifted. For information on the COVID-19 waivers and guidance, and the Interim Final Rule, please go to CMS COVID-19 flexibilities webpage: https://www.cms.gov/about-cms/emergency-preparedness-response-operations/current-emergencies/coronavirus-waivers

Please remember, in the CY 2020 PFS final rule time was addressed for EM services.  “On an interim basis, we are revising our policy to specify that the office/outpatient E/M level selection for these 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 requirements regarding documentation of history and/or physical exam in the medical record….We note that currently there are typical times associated with the office/outpatient E/Ms, and we are finalizing those times as what should be met for purposes of level selection”. 

We are recommending that you record the time within the visit note on both telephone and telehealth visits.

We are here and trying our best to stay on top of the coding issues.  Please feel free to e-mail if you need anything.  Stay Safe.


© 2021, Auditing for Compliance & Education, Inc.