How to Bill for Telehealth During the COVID-19 Pandemic

CMS, at the order of the U.S. legislature, has altered some practices to address the coronavirus crisis better. Loosening restrictions on telehealth or telemedicine reimbursement is one of the most significant changes that the government has enacted. In the past, CMS reimbursed for these services on a limited basis only. As of recent regulatory changes, providers can now bill for telehealth visits at the same rate as in-person visits during this emergency declaration period. Now, providers have much more freedom to see patients via phone or virtual visits using interactive apps, such as Otto Health Telehealth or Zoom, instead of in person. This step allows patients to get at least some of the health care they need without leaving home and increasing their chances of contracting the virus. It also helps your physicians, nurses, and staff stay safe during the pandemic. This temporary regulatory change is particularly helpful for keeping patients with COVID-19 symptoms at home where they are not spreading the virus. It also helps the elderly with multiple comorbidities for whom the virus is particularly dangerous.

Of course, these changes pose some challenges for already overburdened staff members, who need to alter their coding for billing practices. Fortunately, the CMS billing guidelines are relatively simple and are based, for the most part, on waiver 1135. These coding practices are already in effect and will remain so until further notice. While CMS is making things simpler, many payers are still catching up to these changes with varying success. As such, confirm with your major payors guidelines prior to submitting telehealth visits.

Prior Relationship

The previous regulations stipulated that CMS would not pay for telemedicine visits unless a previous relationship existed between the patient and the physician. For the duration of the current crisis, that rule has been waived. Or, more precisely, the HHS will not conduct audits during this medical emergency to determine if a prior relationship existed. This policy change means that providers have an opportunity to offer telehealth care to many more patients, especially vulnerable populations. Your billing personnel may not have much experience in submitting telehealth claims, however. In response, the CMS has offered clear guidelines on which codes should be used to receive timely reimbursement. They are as follows:

Bill Medicare Telehealth Visits

A telehealth visit is defined as "a visit with a provider that uses telecommunication systems between a provider and a patient." Common codes for these visits include:

• 99201-99215: Office or other outpatient visits

• G0425-G0427: Telehealth consultations, emergency department or initial inpatient

• G0406-G0408: Follow-up inpatient telehealth consultations furnished to beneficiaries in hospitals or SNFs

The relaxed rules have the biggest effect on this type of telehealth visit. You can use these codes for new or established patients for the duration of the healthcare emergency instead of for established patients only.

Virtual Check-in

These telehealth visits are still covered for established patients only and consist of a short check-in by telephone or computing device. They are most often used to decide if a patient needs an office visit or some other medical service. Your staff may use the following codes for billing:

• HCPCS code G2012

• HCPCS code G2010

Again, these visits generally take only five to ten minutes and are not meant to substitute for an in-person or telehealth office visit.

E-Visits

E-visits are defined as "a communication between a patient and their provider through an online patient portal." The appropriate codes for these visits include the following:

• 99421

• 99422

• 99423

• G2061

• G2062

• G2063

Like check-ins, these codes still reflect a visit with an established patient. The provider relationship regulation is only waived for Medicare telehealth visits.

Other Visits

Telehealth visits have now been expanded to include emergency department visits, initial nursing facility and discharge visits, home visits, and therapy visits.

Telehealth Modifiers

There are no new modifiers required by the CMS. There are still three cases where existing modifiers should be used:

1. GQ modifier - When "a telehealth service is furnished via asynchronous (store and forward) technology as part of a federal telemedicine demonstration project in Alaska and Hawaii..." 

2. GT modifier - When you bill the telehealth service under CAH Method II

3. G0 modifier - Necessary when the telehealth service is used to diagnose and treat an "acute stroke."

Place of Service Change

Further changes to telehealth services were announced on March 30. Per the CMS, the place of service (POS) code 02 should no longer be used when submitting these claims. Instead, submit the code for the location that would have been used if you were able to see the patient in person. This change means that you will be paid at the higher non-facility rate.

Important Telehealth Billing Stipulations

Many in the medical community hope that more telehealth visits will continue to be covered after the medical emergency is over since telehealth visits routinely benefit the elderly, the chronically ill, and those in rural areas. As of now, however, these changes are temporary.

CMS stresses that these telehealth services are not limited to certain geographical areas and that out-of-state doctors can temporarily participate in them without being licensed in the patient's state.

You are allowed to inform your patients that these services are available, but you are not allowed to initiate a specific telehealth visit with them. That contact must come from the patient to meet federal regulations.

To ease provider concerns, the OCR is currently waiving HIPAA fines against providers who are using telemedicine in good faith through communication technologies. They recognize that many providers are new to this type of service and may inadvertently violate some HIPAA tenants while delivering medical services.

On March 30, the President ordered more changes to telehealth regulations, allowing 80 more services to be conducted and billed as telemedicine. Doctors were also granted more power to supervise staff remotely as well.

Finally, the Medicare coinsurance and deductible generally applies to these services, even during this medical crisis.

The TempDev Advantage

The expert billing consultants at TempDev understand how this crisis has overloaded many providers throughout the United States and the rest of the world. You have to adapt to an unprecedented pandemic in a matter of days, so you need access to all the advanced tools available.

NextGen Healthcare EPM & EHR software can make dealing with this healthcare emergency easier by simplifying your billing practices, including those involving telehealth visits. The TempDev team can help you determine the best course of action for updating your system to meet the billing needs of telehealth visits.

There are various options that can be updated within NextGen to ease workflow and bill efficiently for telehealth visits. 

In addition to billing help, you can use NextGen EHR templates to set up contagion tracking to assess better the risk of exposure and COVID-19 development among your patients. Read more about how to configure the NextGen EHR for COVID-19.

Providers and other healthcare workers are on the front line of this pandemic. The number of infected patients and those needing hospitalization is not expected to peak for weeks or possibly months, so the strain will be ongoing. TempDev stands ready to help you cope in any way possible, including with configuration advice, ongoing training, and even staff augmentation. We have solutions that can immediately help you and your staff deal with this once-in-a-lifetime crisis. Contact us at 888.TEMP.DEV or here to get your questions answered.