Terminology being used may be confusing for many providers and coders:

  • Virtual Visits –typically telephone calls, some definitions all secure email, or video call.
    • Medicare: G2010 and G2012 – only 5-10-minute appointments
    • Private 99441-99443 – 5-10 & 10-20-minute appointments.
  • E-visits – Typically these visits involve the use of a patient portal
    • Medicare and private: 994421, 99423, 99423
  • Telehealth – in-person visit with audio and video; technology just must not be public facing like Zoom or Apple’s Facetime
    • Commercial: might be different some payers will call everything a virtual visit.
    • These are typically coded as E&M codes like 99201 – 99211
    • Ensure that all documentation points to a telehealth visit otherwise the payment could be rejected.
  • All visits must be patient initiated to be covered under new emergency guidelines – this does not include provider-initiated visits like those for chronic illness management.

Questions on Rural Health Clinics:

  • It is still unclear how the CARES Act affects RHCs. Many clinics are adding the CG modifier, but this has to be truly a face-to-face visit to be paid at an all-inclusive rate; for example an audio only call would not billed with this modifier. Some previously existing requirements might still be in place.
  • As of March 1st, 99421-99423 have been added doubling the reimbursement of telehealth still put with a modifier of 521 but billed through Medicare. If basing your fee on Medicare fee schedule, your practice will be charged at the lowest amount.

What codes should an RHC use for virtual visits vs. telehealth

  • G0071 – now included to pay a single fee-scheduled amount. Any other normal code (like 99421-99243) would be coded at this amount.

What should be included in consent for telehealth?

  • Verbal consents – as part of registration the providers or support should document consent for the median used. With minors, its also important to document parental consent and that the parents are present.

Do providers need to document start and stop for telehealth RHC?

  • Billing can occur either based on time or medical decision making – documenting both will help, but at the very least document total time.

Should RHCs work to send claims in immediately or wait?

  • It’s important to wait to receive the proper guidance for payments otherwise large scale denials could hold up payments.
  • According to NARHC – RHCs have received Medicare money and can expect to a new rounds of stimulus to focus on Medicaid reliant facilities and areas.

How to bill for an solely audio telephone call?

  • G2012: most typically appropriate for these kinds of visits.
  • G2010: store and forward might be appropriate if information from the patient was sent prior to the calln.
  • 99421-99423: mostly used by private payers

How can CAH code for for telephone visits?

  • A provider-based clinics will use the same codes but documentation must support that the provider on the call was an eligible provider.

Can 99201-99205 with modifier -95 on a telehealth visit and place of service modifiers can still be billed?

  • Unclear check with payers?

How to bill properly for COVID: Creating a matrix

  • For each of your practices common payers create a list of allowances; for example, if a payer is waiving fees for telehealth ensure that there’s no caveats to that e.g. the insurance requires using their portal. This will aide in communication with the patient and garnering consent.
  • For example, some payers want a -02 modifier, but it’s important to ensure that payers are planning to pay out at the highest available rate. Some payers may pay based on the lower facility rate, but many states are requiring the higher -11 office rate.
  • There are also inconsistencies with place of service modifiers vs. geographic modifiers vs. some other mechanism; insurance companies are still developing guidelines.

What’s the turnaround time for payments? Will remits from payers have specific notes like ‘following COVID-19’ guidelines?

  • Unclear – many systems for proper reimbursement have not been set-up.

Can a physical therapist conduct outpatient visits for a CAH?

  • No – as of 4/15/2020. The interim codes by CMS have been updated, but the list of providers able to provide telehealth has not been expanded to include PTs.

Can LIMHPS and LMNHPS be paid for telehealth visits?

  • Currently not eligible providers by Medicare but certain states’ Medicaid might allow their usage.

How to properly code for lab tests?

  • Currently the codes are U0001 for CDC labs and U0002 for non-CDC labs.
  • A code 87635 was newly added for antibodies test but this is still unclear.

Can the 99441-99413 be used by RHCs?

  • The 99441-99413 are not to be used by RHCs – no instruction waiving this rule has been issued. G0071 is a Medicare code that covers any care qualifying care on G2010-G2012.

How Should an RHC code place of service for non-face-to-face visits?

  • The place of services codes should be a -052 code indicating that the patient is ‘in the current.’ This is only available during the crisis.