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Telehealth Coding and Billing During COVID-19

Last updated 5/22/2020

During the COVID-19 public health emergency, telehealth offers medical practices the ability continue caring for their patients, both those with and those without COVID-19. In order to mitigate exposure of patients who are sick or at-risk due to other conditions, as well as protect the healthcare workers and community, practices are strongly encouraged to use telehealth whenever possible and to consider establishing protocols and procedures for use by practice staff and clinicians.  Now in a full state of emergency, many Medicare restrictions related to telehealth have been lifted.  

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Patients can be at home and non-HIPAA compliant technology is allowed. There is no cost sharing for COVID-19 testing. In addition, to encourage use by patients, Medicare is allowing practices to waive cost sharing (copays and deductibles) for all telehealth services, and much prior authorization activities are being paused.

IMPORTANT NOTES:

  • Some states and some payers are reimbursing for telehealth (some including audio-only telephone calls) at the same rates as in-person visits. While we have tried to keep up with all the policy changes, it is important to check the policy announcements from your own state and payers.
  • Additionally, during the COVID-19 public health emergency, rural and site limitations are removed. Telehealth services can now be provided regardless of where the enrollee is located geographically and type of site, which allows the home to be an eligible originating site. However, locations that are newly eligible will not receive a facility fee.

Telemedicine: A Practical Guide for Incorporation into your Practice

ACP's new online CME program provides crucial information to physicians looking to begin or expand the use of telemedicine during the COVID-19 outbreak. It includes guidance about coding and using telehealth, CME/MOC is free to ACP members.

Start Activity

Downloadable Supplements

Telemedicine Options

Many Medicare restrictions related to virtual visits have been lifted during the national medical emergency. The following criteria apply to Medicare visits during the emergency.

  • CMS has issued additional guidance regarding flexibilities specific to FQHCs and RHCs.
  • Informed Consent for Telehealth:  Although it is not always required, it is important that patients understand the risks and benefits of using telehealth.  AHRQ has a simple, customizable consent form and how-to guidance for clinicians on how to explain telehealth.  Document verbal consent prior to each telehealth visit until you can receive a signed consent (either digitally or on paper) from the patient. 

Note: This information provides coding guidance, and national average Medicare payments when available.  Due to state and private payer policy and other differences, it does NOT guarantee reimbursement.

Virtual Check-in

  • Can be any real-time audio (telephone), or "2-way audio interactions that are enhanced with video or other kinds of data transmission."
  • Communication can use non-HIPAA compliant technology during the COVID-19 public health emergency.
  • New or established patients.
  • Any chronic patient who needs to be assessed as to whether an office visit is needed. 
  • Patients being treated for opioid and other substance-use disorders.
  • Nurse or other staff member cannot provide this service. It must be a clinician who can bill E&M services.
  • If an E&M service is provided within the defined time frames, then the telehealth visit is bundled in that E&M service. It would be considered pre- or post-visit time of the associated E&M service and thus not separately billable.
  • No geographic restrictions for patient location. 
  • Should be initiated by the patient since a copay is required. Verbal consent to bill and documentation is required.
  • No modifier needed as these are technology based codes.

Code

Description

Fac Fee

Non-Fac Fee

G2010

Remote evaluation of recorded video and/or images submitted by an established patient (e.g. store and forward), including interpretation with followup with the patient within 24 business hours, not originating from a related E&M service provided within the previous 7 days nor leading to an E&M service or procedure within the next 24 hours or soonest available appointment.

$9.38

$12.27

G2012

Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report E&M services, provided to an established patient, not originating from a related E&M service provided within the previous 7 days nor leading to an E&M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.

$13.35

$14.80

Online Digital Evaluation and Management (E/M)

These services are not for the non-evaluative electronic communication of test results, scheduling of appointments, or other communication that does not include E/M. While the patient’s problem may be new to the clinician, the patient must be an established patient.

  • Can be done synchronously and asynchronously and audio/video phone can be used (but not a traditional telephone).
  • Must be patient initiated.  The patient can initiate a virtual check-in, the practice can let the patient know about their options. If the patient calls back within 7 days, then the time from the virtual check-in can be added to the digital E/M code and only the digital E/M code is billed. Cost sharing applies to the E/M service; copays are waived for COVID-19 testing, but deductibles still apply.
  • Use only once per 7-day period.
  • Clinical staff time is not calculated as part of cumulative time
  • Service time must be more than 5 minutes
  • Do not count time otherwise reported with other services
  • Do not report on a day when the physician or other qualified health care professional reports E/M services
  • Do not report when billing remote monitoring, CCM, TCM, care plan oversight, and codes for supervision of patient in home, domiciliary or rest home etc. for the same communication[s])
  • Do not report for home and outpatient INR monitoring when reporting 93792, 93793)
  • If the patient presents a new, unrelated problem during the 7-day period of an online digital E/M service, then the time is added to the cumulative service time for that 7-day period.
  • No modifier needed as these are technology based codes.

If the patient initiates a call to the physician office this would qualify for the remote check-in code (G2012), the time for the remote (virtual) check-in can be counted toward 99421-3 only if and when the patient calls back, so it is important to document the time. (See CPT book for further details regarding when the 7 days begins, how to count time, which “qualified non-physician health professionals” it applies to, and other documentation requirements.

Code Description Fac Fee Non-Fac Fee
99421 Patient-initiated digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes 13.35 15.52
99422 ….11-20 minutes 27.43 31.04
99423 ….21 or more minutes 43.67 50.16

Remote Monitoring

  • New or established patients.
  •  During the duration of the COVID19 PHE, remote monitoring can be reported for periods of time 2 days or longer (thus removing the 16-day minimum).
  • Followup can be by phone, audio/video, secure text messaging, email or patient portal communication.
  • Involves "asynchronous transmission of healthcare information" from the patient. If the images are not sufficient to perform the evaluation, then do not bill for the service.
  • If an E&M service is provided within the defined time frames, then the telehealth visit is bundled in that E&M service. It would be considered pre- or post-visit time of the associated E&M service and thus not separately billable.
  • Should be initiated by the patient since a copay is required. Verbal consent to bill and documentation is required.
  • This is distinct from CCM code 99490 (CCM), which can be provided without the patient's presence and use any means of communication.
Code Description Fac Fee Non-Fac Fee
99453 Remote monitoring of physiologic parameter(s) (eg, weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education on use of equipment 18.77 18.77
99454 Remote monitoring of physiologic parameter(s) (eg, weight, BP, pulse oximetry, respiratory flow rate) initial; device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days 62.44 62.44
99457 Remote physiologic monitoring treatment management services, 20 minutes or more of clinical staff, physician, or other qualified health professional time in a calendar month requiring interactive communication with the patient/caregiver during the month 32.84 51.61

For the online assessment codes, it is expected that these services would be patient initiated, but practices may educate their patients about the availability of the service. For more detailed information about how to use these codes, see ACP’s Telehealth Toolkit.

Telephone Calls

For the duration of the PHE, audio-only telephone calls that are used as a replacement for care that would otherwise be billed as in-person or telehealth will be paid the equivalent amount of E&M codes 99212-99214. This change is effective April 30 and is retroactive from March 1, 2020.

As of May 15, CMS states that MACs will reprocess claims for those services previously denied and/or paid at the lower rate. Private payers may have different rules regarding how to bill care provided by audio-only telephone.  Claims billed after April 30 should be paid at the new rate.  We suggest that practices change the fees in the practice’s billing system for these 3 codes to the new higher rate.

  • No modifier is needed for these codes because they are not telehealth – they are audio only telephone.
  • Use your normal Place of Service.  For instance, POS=11 (private practice).  (Use of POS 02 will result in lower payment.)
  • Can be used for new or established patients.
  • Document verbal consent (because of cost-sharing requirements) and why in-person or audio-video encounter not possible.
Code Description Work RVU Revised Work RVU
99441 Telephone E/M service provided by a physician to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hrs or soonest available appointment, 5-10 medical discussion .25 .48
99442 …11-20 minutes .50 .97
99443 …21-30 minutes .75 1.50

CMS new policy based on the Interim Final Rule from 3/31 states that these codes are covered and can be billed retroactively from March 1, 2020.

Allowed Telehealth Services

All E/M and other services that are currently eligible under the Medicare telehealth reimbursement policies are included in this waiver. These are list of eligible CPT/HCPCS codes, including which codes are allowed to use audio-only telephone. Use modifier -95 to claim lines that describe the services provided via telehealth. POS code would be whatever would have been reported had the service been provided in person. See the “Modifiers” section below for more information about how to correctly bill for these CPT services.

Modifiers

-95: Telehealth services provided via real-time interactive audio and video should be billed with the place of service (POS) code that would have been used had the service been provided in person, such as POS=11 (private practice) instead of 02 (telehealth).

  • Append modifier -95 to all telehealth services billed using POS 11. This change will enable providers to be reimbursed at the same rate as services provided in person.
  • During the current COVID-19 Public Health Emergency, telehealth E/M levels can be based on Medical Decision Making (MDM) OR time (total time associated with the E/M on the day of the encounter). Likewise, CMS has also removed any requirements regarding documentation of history and/or physical exam in the medical record for Telehealth visits.
  • Modifier -95 should not be used with virtual visits (G2012) or the digital evaluations (99421-99423). It is for use with all other telehealth codes that use synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system.

-CS: Use on applicable claim lines subject to the cost-sharing waiver (i.e., COVID-19 testing-related services). Medicare beneficiaries should not be charged for any coinsurance or deductible for those services. The -CS modifier will signal the Medicare Administrative Contractors (MACs) to pay 100% of the Medicare-approved amount for the service. Physicians should contact their MACs and request to resubmit applicable claims with dates of service on or after March 18, 2020, that were submitted without the -CS modifier. The -CS modifier should not be used for services unrelated to COVID-19.

-GQ: Clinicians participating in the federal telemedicine demonstration programs in Alaska or Hawaii must submit the appropriate CPT or HCPCS code for the professional service along with the modifier GQ, “via asynchronous telecommunications system.”

-GO: Use of telehealth for purposes of diagnosing stroke.

Note:  Medicare stopped the use of modifier -GT in 2017 when the place of service code 02 (telehealth) was introduced.  However, private payer may still be using the modifier -GT.

No modifiers are needed for telephone calls (99441-99443) as they are not considered telehealth.  

Revving Up Your Telemedicine Practice in the Time of COVID

View a recorded webinar presented by ACP, the Southwest Telehealth Resource Center, and Arizona Telemedicine Program. Focused on ambulatory care, the webinar outlines key principles of telehealth care, steps to starting video visits, approaches to the tele-physical exam, elements for successful telemedicine workflow integration, and other resources and logistics to consider during this emergency period. Watch Webinar

COVID-19 Billing

This CMS FAQ provides information about cost-sharing requirements for COVID-19 testing and treatment. 

ICD10 Codes

Code only confirmed diagnosis as documented by the clinician, documentation of a positive test result, or a presumptive positive test result.

U07.1 - ​2019-nCoV acute respiratory disease.  Effective April 1, 2020, the CDC has issued a new ICD10CM emergency code.  

If the clinician document “suspected,” “possible,” “probable,” or “inconclusive, assign a code explaining the reason for the encounter

Z20.828 - ​Contact with and suspected exposure to other viral communicable diseases (actual exposure)

Z03.818​ - Encounter for observation for suspected exposure to other biological agents ruled out (possible exposure, but ruled out after evaluation)

Z11.59​ - Encounter for screening for other viral diseases (for asymptomatic individuals being screened for COVID-19, have no know exposure to the virus, and test results are either unknown or negative)

Sequencing:  U07.1 should be the primary diagnosis, followed by appropriate codes for associated manifestations:

  • J12.89 (other viral pneumonia)
  • J20.8 (acute bronchitis due to other specified organisms)
  • J22 (unspecified acute lower respiratory infection NOS)
  • J40 (bronchitis, not specified as acute or chronic)
  • J80 (acute respiratory distress syndrome)
  • J98.8 (other specified respiratory disorders)

Use appropriate codes for the signs and symptoms, e.g., R05 (cough), R06.02 (shortness of breath), or R50.9 (fever, unspecified)

For more detailed guidance regarding diagnosis coding for COVID-19 and guidelines for pregnant patients, see this CDC guideline.

Lab Codes

On April 30, CMS issued guidance providing additional flexibilities related to lab orders.  

Patients no longer need to see a physician in order to receive a written order for testing.  COVID-19 tests will be covered when ordered by any healthcare professional authorized to do so under state law. For a complete list of COVID-19, influenza, and RSV clinical diagnostic laboratory tests for which Medicare does not require a practitioner order during the PHE, click here.

For a summary of Medicare payments for lab testing by type of test and location, see here.  

87635 - ​Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique.

86328 - ​Immunoassay for infectious agent antibody(ies), qualitative or semiquantitative, single step method (eg, reagent strip); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (COVID-19).

86769 - Antibody; severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (COVID-19)(multi-step method).

99000 - ​Handling and/or conveyance of specimen for transfer from the physician’s office to a laboratory. (Use if the specimen is prepared by your office and sent to an outside lab, report the specimen collection code.)

99001 - Handling and/or conveyance of specimen for transfer from the patient in other than an office to a laboratory (distance may be indicated) (Use when directing patient to a testing site.)

The Centers for Medicare & Medicaid Services (CMS) developed new lab testing codes:

U0001​ - Use to report coronavirus testing using the CDC 2019 Novel Coronavirus Real Time RT-PCR Diagnostic Test Panel.

U0002 - ​​Use to report validated non-CDC laboratory tests for SARS-CoV-2/2019-nCoV (COVID-19).

U0003 - ​Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique, making use of high throughput technologies.  Note: Use for tests that would otherwise be identified by CPT code 87635 but for being performed with high throughput technologies.

U0004 - 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19), any technique, multiple types or subtypes (includes all targets), non-CDC, making use of high throughput technologies.  Note: Use for tests that would otherwise be identified by U0002 but for being performed with these high throughput technologies.

C9803 - ​Specimen collection only. For use by outpatient hospital departments when no other services were provided. Physician offices should use 99211.

The AMA has issued some coding guidance that includes how to code different scenarios (Updated May 4). The scenarios include examples specifically related to COVID-19 testing. For example, coding for when a patient comes to the office for E/M visit, and is tested for COVID-19 during the visit; receives a telehealth visit re COVID-19 and is directed to come to physician office or physician’s group practice site for testing; receives a virtual check-in/online visit re COVID-19 (not related to E/M visit), and is directed to come to physician office for testing; and more. [Note: These only address coding and are not a guarantee of reimbursement.]

Note regarding Originating Site: During the COVID-19 public health emergency, rural and site limitations are removed. Telehealth services can now be provided regardless of where the enrollee is located geographically and type of site, which allows the home to be an eligible originating site. However, locations that are newly eligible will not receive a facility fee.

Telehealth Technology

More information on technology options for providing telehealth services, including options to address the emergent pandemic as well as longer-term options for your practice.

Tech Options