UPDATE: FEDERAL REGISTER INTERIM CMS-1744-IFC COVID-19 PUBLIC HEALTH EMERGENCY

“Buckle up…things move fast around here”

On Friday evening, PalmettoGBA issued a coding change and billing clarification for telehealth services provided during the public health emergency. These changes are based on a Federal Register Interim document issued on 4/1/20 (pending comment period). They have updated a couple of things that will affect your claims if you are billing for these services.

First, CMS has opened up these types of telemedicine visits to NEW, emergency patients. So new patient E/M codes will be covered if you need to see a new patient via FaceTime, Skype, or other.

Next, the Place of Service (POS) code that CMS originally designated for telehealth services is 02. Due to edits in their system causing denials, they have changed the POS requirements to report that POS where the E/M services you are providing would normally take place, i.e. the office. So, you do not need to update your POS codes on these claims any longer!

Lastly, remember that E/M services must be documented to reflect the level of service that you are billing. Medical necessity is still the overarching criterion for all billed services. It is true that they are relaxing regulations and the auditing of certain records in the immediate. This does not mean that they won’t audit at a later date, so document, document, document. 
Review Checklist and Score Sheet Tool from Palmetto: Checklist tool for New Patient and Established Patient E/M www.palmettogba.com > Jurisdiction J Part B MAC > Forms/Tools > E/M Scoresheet Tool > New Pt / Est Pt

Also available:

VIRTUAL CHECK-IN CODING

G2012 Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management 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 (-95 modifier DOES NOT APPLY)

G2012 Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management 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 (-95 modifier DOES NOT APPLY)

Hopefully you have reviewed your liability policies for telehealth coverage and are able to participate in telemedicine services for your Medicare and Medicare Advantage plan patients. Be sure your documentation is reflecting the way that the visit was observed (i.e. Skype, etc.) and the time spent on the telehealth visit as well as the history, exam, and medical decision-making documentation needed to correctly bill for the level of care. Your plan would need to determine follow up for the issue as well as missing elements (IOP, etc.) that will be reviewed when the patient can safely return to the office.

Sign your encounters, gang.

Be safe everyone!

Krystin Keller, CPC
Keller Consulting Connection
GOA Coding and Billing Contact