What you need to know about payment parity, coding, advocacy and more from our experts.
Payment parity
CMS' announcement of telehealth reimbursement payment parity is a huge win for our community. After weeks of active engagement to CMS, Congress and the administration, CMS announced that it will reimburse audio-only E/M telehealth visits at the same rate as in-person rates. Thank you to all the members that engaged and took action on this issue. Your involvement was critical to our success.
How to code to maximize your reimbursement
Rules for coding for telemedicine have changed a lot since the beginning of the COVID-19 public health emergency (PHE). To ensure Medicare payment at rates equivalent to E/M codes 99212-99214, report modifier 95 and the place of service where the visit would have happened in person if not for the public health emergency.
Some commercial payers cover telephone E/M visits, but you'll need to check each patient's individual plan.
Here are some tips for telemedicine/virtual visit coding for Medicare patients:
Telehealth E/M (video visits) – Medicare requires a real-time audio and video connection to report E/M as telehealth. During the COVID-19 PHE, E/M level selection (99201-99205, 99211-99215) can be made based on medical decision making or time. If selecting based on time, you may use either the 2020 or 2021 times in the E/M code descriptions. For Medicare, time is counted as the total spent on the day of the visit, not just face-to-face time. Commercial payors typically count only face-to-face time but check with each commercial patient's plan to be sure. Don't forget to report modifier 95 and the place of service where the visit would have happened in person if not for the PHE. If you had trouble with the connection and needed to switch to a telephone call, you can still report the visit as telehealth if over 50% of it was completed using the real-time audio/video platform or app.
Telephone E/M - Medicare now pays for telephone E/M codes 99441-99443 at the same rates as office/outpatient established patient E/M codes 99212-99214, but you must report modifier 95 and the place of service where the visit would have happened in person if not for the PHE. Medicare will also allow reporting of telephone E/M for new or established patients.
Online digital E/M – Medicare allows communication with patients via the practice's online patient platforms to be reported with codes 99421-99423. These codes are not considered telehealth services, so no special modifiers are required. They must be patient initiated. Communications can occur over a seven-day period via portal, fax, or phone or a combination. Do not report online digital E/M codes if the online patient request is related to an E/M service within the previous seven days or within the global period.
Virtual check-ins – Medicare created virtual check-in codes G2010 and G2012 in 2019. According to the CMS, they were created for "a 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." The virtual visit codes can still be used this way during the COVID-19 PHE but remember that CMS also allows coverage for telephone E/M (99441-99443) which may be a more appropriate choice for telephone calls depending on the nature of the request and the patient's clinical issues.
Review AGA's telehealth coding and coverage guide for more details. To see FAQs on telemedicine from the AGA Community, check out GI COVID-19 Connection: Telemedicine for Today's GIs.
With telehealth serving as the main mechanism to deliver care to patients and a lifeline to private practices, we understand this is a priority for you and your colleagues. With the Alliance of Specialty Medicine, we continue to urge CMS to make the payment parity and eased telehealth waivers and regulations permanent beyond the public health emergency.
