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To help patients receive medical care without having to travel to a healthcare facility, Medicare and many commercial payers announced in March 2020 that they will lift geographical restrictions and will pay for telehealth services in all areas of the country and in all settings, for the duration of the COVID-19 Public Health Emergency. CMS Telehealth visits are paid at the same rate as regular, in-person visits. See the complete list of all Medicare telehealth services here

Prior to this temporary telehealth expansion, CMS made several changes to improve access to virtual care. In 2019 and 2020, Medicare started making payment for many other telemedicine services (see blog post "What is new in 2019 for Telehealth and Telemedicine?")

This blog post summarizes CMS coding, coverage and reimbursement information on some of the telemedicine services that are relevant to the wound care healthcare professional. Roughly, these telemedicine services can be classified as intended for communication between provider and patient and between providers about a patient. For details on restrictions and requirements per CMS and AMA, see 'Sample TeleVisit Workflows' in topic "Telemedicine/ Televisit Implementation Playbook - Part 2". For descriptions of CPT codes commonly used in wound care telemedicine, see topic "Telemedicine Coding for Wound Care".

Telemedicine services for communication between provider and patient

Brief communication technology-based service, e.g. virtual check-in (HCPCS code G2012)

  • Practitioners are separately paid for the brief communication technology-based service when the patient checks in with the practitioner via telephone or other telecommunications device to decide whether an office visit or other service is needed. This increases efficiency for practitioners and provides convenience for beneficiaries.

Remote evaluation of recorded video and/or images submitted by an established patient (HCPCS code G2010)

  • Service of remote evaluation of recorded video and/or images submitted by an established patient will allow practitioners to be separately paid for reviewing patient-transmitted photo or video information conducted via pre-recorded “store and forward” video or image technology to assess whether a visit is needed. 

Online digital evaluation and management services or e-Visits for an established patient (CPT 99421-99423 and G2061-G2063 or CPT 98970-98972 for some commercial payers)

  • These services are "patient-initiated digital communications that require a clinical decision that otherwise typically would have been provided in the office." Under the original code description, an online patient portal is required.
    • CPT codes 99421-23: time-based codes billed by physicians and qualified healthcare professionals for "Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days". Reimbursed in increments of 5-10 minutes (99421), 11-20 minutes (99422), and 21 or more minutes (99423)
    • HCPCS codes G2061-63 or CPT 98970-98972 for some commercial payers: similar to the CPT codes above, but can be billed by practitioners who cannot independently bill E/M services, for "Qualified nonphysician healthcare professional online assessment, for an established patient, for up to seven days, cumulative time during the 7 days". Reimbursed in increments of 5-10 minutes (G2061), 11-20 minutes (G2062), and 21 or more minutes (G2063)

CMS flexibilities to fight COVID-19 (3/30/20) and Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency (4/6/20) [CMS-1744-IFC]  

    •  Established and new patients: Clinicians can provide Communication Technology-Based Services (CTBS, HCPCS codes G2010, G2012 and 99421-23 or G2061-63) to both new and established patients. Those services were previously limited to established patients.  

    Telehealth services

    CMS flexibilities to fight COVID-19 (3/30/20) and Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency (4/6/20) [CMS-1744-IFC]  

  • New telehealth codes: Clinicians can now provide more services to beneficiaries via telehealth so that clinicians can take care of  their patients while mitigating the risk of the spread of the virus. Under the public health emergency, all beneficiaries across the country can receive Medicare telehealth and other communications technology-based services wherever they are located. Clinicians can provide these services to new or established patients. In addition, providers can waive Medicare copayments for these telehealth services for  beneficiaries in Original Medicare.  To enable services to continue while lowering exposure risk, clinicians can now provide the following  additional services by telehealth: 
      • Emergency Department Visits, Levels 1-5 (CPT codes 99281-99285)
      • Initial and Subsequent Observation and Observation Discharge Day Management (CPT codes  99217- 99220; CPT codes 99224- 99226; CPT codes 99234- 99236)
      • Initial hospital care and hospital discharge day management (CPT codes 99221-99223; CPT  codes 99238- 99239)
      • Initial nursing facility visits, All levels (Low, Moderate, and High Complexity) and nursing facility discharge day management (CPT codes 99304-99306; CPT codes 99315-99316)
      • Critical Care Services (CPT codes 99291-99292)
      • Domiciliary, Rest Home, or Custodial Care services, New and Established patients (CPT codes  99327- 99328; CPT codes 99334-99337)
      • Home Visits, New and Established Patient, All levels (CPT codes 99341- 99345; CPT codes  99347- 99350)
      • Inpatient Neonatal and Pediatric Critical Care, Initial and Subsequent (CPT codes 99468- 99473;  CPT codes 99475- 99476)
      • Initial and Continuing Intensive Care Services (CPT code 99477- 994780)
      • Care Planning for Patients with Cognitive Impairment (CPT code 99483)
      • Psychological and Neuropsychological Testing (CPT codes 96130- 96133; CPT codes 96136- 96139)
      • Therapy Services, Physical and Occupational Therapy, All levels (CPT codes 97161- 97168; CPT codes  97110, 97112, 97116, 97535, 97750, 97755, 97760, 97761, 92521- 92524, 92507)
      • Radiation Treatment Management Services (CPT codes 77427)
      • Licensed clinical social worker services, clinical psychologist services, physical therapy services,  occupational therapist services, and speech language pathology services can be paid for as  Medicare telehealth services.
  • Removal of Frequency Limitations on Medicare Telehealth: To better serve the patient population that would otherwise not have access to clinically appropriate in-person treatment, the following services no longer have limitations on the number of times they can be provided by Medicare telehealth:
      • A subsequent inpatient visit can be furnished via Medicare telehealth, without the limitation that the telehealth visit is once every three days (CPT codes 99231-99233);
      • A subsequent skilled nursing facility visit can be furnished via Medicare telehealth, without the limitation that the telehealth visit is once every 30 days (CPT codes 99307-99310)
      • Critical care consult codes may be furnished to a Medicare beneficiary by telehealth beyond the  once per day limitation (CPT codes G0508-G0509)
  • Beneficiary consent: Beneficiary consent should not interfere with the provision of telehealth services. Annual consent may be obtained at the same time, and not necessarily before, the time that services are furnished. 
  • Physician visits for nursing homes: CMS is waiving the requirement in 42 CFR 483.30 for physicians and non-physician practitioners to perform in-person visits for nursing home residents and allow visits to be conducted, as appropriate, via telehealth options.
  • Practitioner Locations: Temporarily waive Medicare and Medicaid’s requirements that physicians and non-physician practitioners be licensed in the state where they are providing services. State requirements will still apply. See Current State Laws & Reimbursement Policies, including medical licensure requirements.
  • Provider Enrollment: CMS has established toll-free hotlines for physicians, non-physician practitioners and Part A certified providers and suppliers establishing isolation facilities to enroll and receive temporary Medicare billing privileges.
  • Telemedicine services for communication between providers about a patient

    Interprofessional internet consultation (CPT codes 99446, 99447, 99448, 99449, 99451, 99452)

    The CPT codes below can only be billed by those practitioners that can independently bill Medicare for E/M services. Patient consent needs to be documented and will be responsible for the corresponding co-payment.

    • CPT 99446: Interprofessional telephone/Internet assessment and management service provided by a consultative physician including a verbal and written report to the patient's treating/requesting physician or other qualified health care professional; 5-10 minutes of medical consultative discussion and review
    • CPT 99447: Same as 99446, but 11-20 minutes of medical consultative discussion and review
    • CPT 99448: Same as 99446, but 21-30 minutes of medical consultative discussion and review
    • CPT 99449: Same as 99446, but 31 minutes or more of medical consultative discussion and review
    • CPT 99451: Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician including a written report to the patient’s treating/requesting physician or other qualified health care professional, 5 or more minutes of medical consultative time
    • CPT 99452: Interprofessional telephone/Internet/electronic health record referral service(s) provided by a treating/requesting physician or qualified health care professional, 30 minutes

    Modifiers

    Modifiers are used to indicate what type of technology was utilized for the telemedicine encounter. Many payers will reject a claim if a modifier is not appended. 

    Modifier Descriptions

    • GQ: Via Asynchronous Telecommunications systems
    • GT: Via Interactive Audio and Video Telecommunications systems
    • 95: Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications system (usually reported only with codes from CPT book Appendix P)
    • G0: Telehealth services for diagnosis, evaluation, or treatment of symptoms of an acute stroke

    For televisits between provider and patients:

    • For e-Visits (CPT 99421-99423 and G2061-G2063): if furnished by a therapist, use GO, GP or GN for Medicare (see box below). Check with your payer (e.g. UnitedHealth does not require a modifier)
    • For virtual check-ins (G2012): if furnished by a therapist, use GO, GP or GN for Medicare (see box below). Check with your payer (e.g. UnitedHealth does not require a modifier)
    • For store-and-forward (G2010): if furnished by a therapist, use GO, GP or GN for Medicare (see box below). Check with your payer (e.g. UnitedHealth does not require a modifier)
    • For telehealth as defined by Medicare: modifier 95 (as defined by CPT book Appendix P: Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications system ) 

    Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency (4/6/20) [CMS-1744-IFC]   

    • Place of Service (POS): CMS is instructing physicians and practitioners who bill for Medicare telehealth services to report the POS code that would have been reported had the service been furnished in person (as opposed to POS 2 for telehealth).This will allow CMS systems to make appropriate payment for services furnished via Medicare telehealth which, if not for the PHE for the COVID-19 pandemic, would have been furnished in person, at the same rate they would have been paid if the services were furnished in person. 
    • Modifier: To facilitate billing of the Communication Technology-Based Services (CTBS) services by therapists for the reasons described above, we are designating HCPCS codes G2010, G2012, G2061, G2062, or G2063 as CTBS “sometimes therapy” services  that would require the private practice occupational therapist, physical therapist, and speech-language pathologist to include the corresponding GO, GP, or GN therapy modifier on claims for these services. CTBS therapy services include those furnished to a new or established patients that the occupational therapist, physical therapist, and speech-language pathologist practitioner is currently treating under a plan of care.

    Medicare Coverage and Payment of Virtual Services (4/3/20)



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    NOTE: This is a controlled document. This document is not a substitute for proper training, experience, and exercising of professional judgment. While every effort has been made to ensure the accuracy of the contents, neither the authors nor the Wound Reference, Inc. give any guarantee as to the accuracy of the information contained in them nor accept any liability, with respect to loss, damage, injury or expense arising from any such errors or omissions in the contents of the work.
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