• Coding for Phone Calls, Internet and Telehealth Consultations


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    Introduction updated on Oct. 20, 2020 with news and link about the administration's extension of the public health emergency due to the COVID-19 pandemic.

    Telemedicine has been available in some form since 2017. During the COVID-19 public health emergency (PHE), both federal and commercial payers have added waivers to expand coverage. Each payer will have their own end date. As of July 2020, the Centers for Medicare and Medicaid Services announced that they are undertaking two concurrent reviews to explore the extension of these waivers. Update: On Oct. 1, U.S. the Department of Health & Human Services (HHS) announced an extension of the public health emergency another 90 days. This latest extension takes effect on Oct. 23 and will expire on Jan. 20, 2021.

    What You Need to Know:

    • Telemedicine refers to a group of services that may be provided to a patient without any physical patient contact. Services may be provided via a telephone (audio) connection, via some type of online communication such as a patient/provider portal, or via email interactions between the patient and practitioner. 
    • Telehealth refers to a distinct level of services that have traditionally been performed via a face-to-face interaction between the patient and physician. Telehealth allows the interaction to still occur face-to-face; however, it can be achieved via audio and video connections.
    • CMS changed place of Service (POS) from 2 to 11. (See "Resubmit Your Telemedicine POS 2 Denied Claims" information below.)
    • Important: Effective April 30, CMS added the Eye visit codes to the list of covered exams during the COVID-19 PHE. Documentation requirements remain the same:
      • 92002 and 92012 are achievable via virtual face-to-face interaction.
      • Place of service is 11 and append modifier -95.
      • This expansion of coverage may be unique to CMS.
    • Time involving staff who are not licensed to practice medicine cannot be billed for or factored into time-based coding options.
    • Important: Effective April 30, CMS included the technician code 99211 as a telemedicine code option. Documentation requirements include:
      • Applies to new and established patients.
      • There must be a documented order from the physician indicating what should be addressed during the staff/patient encounter by phone.
      • Supervision may be virtual.
      • 99211 continues to be bundled with all testing services performed the same day.
      • A physician visit performed on the same day of 99211 would not be separately billable.
    • Commercial and Medicaid programs have their own rules regarding coverage of codes, modifiers and place of service (POS). Check every commercial and Medicaid website for specific information.
    • All information applies to new and established patients.
    • Patients must be notified that a claim will be submitted to the payer.
    • Phone call codes G2012 or 99441-99443 should not be reported when originating from a related E/M service provided within the past seven days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment. Should not be reported for postop visits. (See note below option 2 chart.)
    • E-visit codes 99421-99423 include up to seven days cumulative time. These codes are not to be used for scheduling appointments or conveying test results.
    • Evaluation of Video or Images code G2010 should be used for remote evaluation of recorded video and/or images submitted by a new or established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related E/M service should be provided within the previous seven days nor leading to an E/M services or procedure within the next 24 hours or soonest available appointment. G2010 and G2012 may be submitted the same day.

    For more information, watch "The Ease of Implementing Telemedicine into Your Practice." Plus, view "Telemedicine: Try It. You'll Like It," a presentation by Academy Secretary for Federal Affairs David B. Glasser, MD. It's part of the Academy's one-hour webinar, "Q&A with Solos and Small Group Practices on the Economic Impact of the COVID-19 Pandemic" and starts at the 0:17:50 mark.

    The "Resubmit Your Telemedicine" section below was added on Aug. 4, 2020.

    Resubmit Your Telemedicine POS 2 Denied Claims

    In the early days of telemedicine, CMS required telemedicine codes to be submitted with place of service (POS) 2 for telehealth. Then, CMS changed it to POS 11 for office. Since then, Medicare Administrative Contractors (MAC) have been receiving hundreds of redetermination requests to change the POS on claims from 02 to 11. For physicians who may not be aware, this type of change to their claims should and can be expedited through the reopening process. Check the unique instructors on your particular MAC website. Self-service re-openings can initiate both claim and line level adjustments within a single transaction. Examples of these adjustments are:

    • Billed Amount
    • Deny Services Billed in Error
    • Diagnosis
    • Modifiers-see exceptions below
    • Month/Day of Service Changes
    • MSP Type
    • Place of Service
    • Procedure Code and Billed Amount
    • Procedure Code, Modifier and Billed Amount
    • Rendering NPI and PTAN
    • Referring NPI
    • Reprocess Claim (without changes)
    • Units and Billed Amount
    • Units, Modifier and Billed Amount

    Overview of Four Covered Options for Medicare Part B Patients

    There are four options for telehealth and other communications-based technology services. This information is based on guidelines from the Centers for Medicare & Medicaid Services.

    Option 1: Telehealth Virtual Two-Way Communication Between Physician and Patient

    Level of exam is based on either physician total time on the date of the encounter (listed below) or medical decision making (MDM) during the PHE.

    CPT Code
    New Patients
    Level of MDM Time Modifiers Place of Service
    99201 Straightforward 10 min

    95

    11
    99202

    Straightforward

    20 min 95 11
    99203

    Low

    30 min 95 11
    99204 Moderate 45 min 95 11
    99205 High 60 min 95 11

    Eye Visit Codes

    CPT Code
    New Patient
    Description Modifiers Place of Service
    92002 New patient
    Intermediate exam
    95 11
    92004 New patient
    Comprehensive exam
    95 11
    CPT Code
    Established Patient
    Level of MDM Time Modifiers Place of Service
    99211 Doesn't qualify 5 min 95 11
    99212 Straightforward 10 min 95 11
    99213 Low 15 min 95 11
    99214 Moderate 25 min 95 11
    99215 High 40 min 95 11

    Eye Visit Codes

    CPT Code
    Established Patient
    Description Modifiers Place of Service
    92012 Established patient
    Intermediate exam
    95 11
    92014 Established patient
    Comprehensive exam
    95 11

    Option 2: Physician/Patient Phone Calls

    CPT Code
    Time Modifiers Place of Service
    G2012 5-10 min N/A 11
    99441 5-10 min N/A 11
    99442 11-20 min N/A 11
    99443 21-30 min N/A 11

    Important:  Effective April 30, CMS increased the allowable of 99441 to 99212, 99442 to 99213 and 99443 to 99214. The increase will be automatically made to March 1 dates of service. These codes are reported for medical discussion with the physician and should not be used for administrative or other non-medical discussion with the patient. Learn more.


    Option 3: E-Visits for Online Digital Services

    CPT Code
    Time Modifier Place of Service
    99421 5-10 min N/A 11
    99422 11-20 min N/A 11
    99423 21 or more min N/A 11

    Option 4: Evaluation of Video and Images

    CPT Code
    Definition Modifier Place of Service
    G2010 Remote evaluation of recorded video and/or images submitted by a new or established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours N/A 11

    The "Interprofessional Telephone..." section below was added on July 13, 2020.

    Interprofessional Telephone/Internet/Electronic Health Record Consultations

    An interprofessional telephone/Internet/electronic health record consultation is an assessment and management service in which a patient’s treating physician (eg, attending or primary physician) requests the opinion and/or treatment advice of a physician with specific specialty expertise (the consultant) to assist the treating physician in the diagnosis and/or management of the patient’s problem without patient face-to-face contact with the consultant.

    CPT Code
    Definition Amount
    99446 Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician, including a verbal and written report to the patient’s treating/requesting physician or other qualified health care professional; 5-10 minutes of medical consultative discussion and review $18.41
    99447 11-20 minutes of medical consultative discussion and review $37.31
    99448 21-30 minutes of medical consultative discussion and review $55.58
    99449 31 minutes or more of medical consultative discussion and review $73.98
    • Place of service is 11 or 22
    • Modifier -95 is not required
    • Verify coverage with non-Medicare payers
    • Telephone/Internet/EHR consultations of less than 5 minutes should not be reported.
    • When the sole purpose of consultation is to arrange a transfer of care or other face-to-face service, these codes are not reported.
    • The patient may be either a new patient to the consultant, or an established patient with a new problem or an exacerbation of an existing problem.
      • However, the consultant should not have seen the patient in a face-to-face encounter within the last 14 days.
    • When the telephone/Internet/EHR consultation leads to a transfer or care or other face-to-face service (e.g., a surgery, a hospital visit, or a schedule office evaluation of the patient) within the next 14 days or next available appointment date of the consultant – these codes are not reported.
    • If more than one telephone/Internet/EHR contact is required to complete the consultation requires (e.g., discussion of test results), the entirety of the service and the cumulative discussion and information review time should be reported with a single code.
    • 99446-99449 conclude with a verbal opinion report and written report from the consultant to the attending or primary physician.

    The section below was updated on Aug. 12, 2020.

    Additional Resources