The Changing Landscape of Telemedicine Billing, Payment, and Reimbursements

Changes in Telemedicine Billing Practices, Reimbursements and Payments

Throughout the COVID-19 pandemic, some payers, including Medicare, are waiving cost-sharing requirements, (i.e., copays and deductibles) for the patients who are being treated or tested for COVID-19. In addition, some payers are choosing to waive cost-sharing requirements regardless of a patient’s diagnosis during this time. Furthermore, because of the COVID-19 public health emergency, the Health and Human Services Office for Civil Rights (OCR) will practice enforcement discretion, waiving Health Insurance Portability and Accountability Act (HIPAA) penalties for health care providers serving patients in good faith using everyday communication technologies (e.g. Zoom, Skype etc.).

The following are the coding requirements for Telehealth/Telemedicine services:

• 99201-99205 — New patient
• 99211-99215 — Established patient
• 99411-99443 — Audio only/Phone consult
• 99421-99423 — New telehealth/E-Visit codes.  Reminder: An E-Visit must be initiated by the patient.
• Modifier 95 for commercial payers (when required)
• CR Modifier for Medicare — Describes an emergency or a catastrophe.

Some commercial payers are requiring that practices use the POS 02 code to identify their telehealth visits, therefore, to guarantee the fastest turnaround times on claims, it is crucial that a practice’s billing department is aware which commercial payers require the use of this POS code. Furthermore, many of the commercial payers who indicate they will cover telemedicine services are advising medical billers to use the E&M codes (99201-99215) for these kinds of remote service appointments. At PrognoCIS, we specialize in medical billing and in revenue cycle management, therefore, our staff remains abreast of all the current changes within the medical billing industry.

The codes below are used for Medicare and are not billed using POS 02:

• G2061: Online assessment and management of an established patient by a qualified health care professional (non-physician) for up to seven days with a cumulative time of 5-10 minutes.
• G2062: Online assessment and management of an established patient by a qualified health care professional (non-physician) for up to seven days with a cumulative time of 11-20 minutes.
• G2063: Online assessment and management of an established patient by a qualified health care professional (non-physician) for up to seven days with a cumulative time of 21 minutes, or longer.
• The non-physician E-Visit codes for commercial payers and the Healthcare Common Procedure Coding System (HCPCS) are CPT codes 98970-98972.

Reimbursements from Medicare for telehealth services are the same as the reimbursements Medicare provides for traditional, in-person visits. A provider must have a license in the state the patient is located.

Medicare’s changes in acceptable remote health care service locations and health care providers:

• Prior to the COVID-19 outbreak, Medicare required that beneficiaries visit a medical facility to receive telehealth services. Now, with Medicare’s 1135 Waiver, patients can receive medical care services via telemedicine while visiting any healthcare facility as well as while sitting in their own home. Since the patient can now receive services at his or her residence, concerns related to contracting COVID-19 at a healthcare facility are eliminated.
• Medicare’s 1135 Waiver has also made it possible for beneficiaries to receive telemedicine services from an array of healthcare providers, including: physicians, physician assistants, nurse practitioners, certified nurse anesthetists, nurse midwives, registered dietitians, licensed clinical social workers, nutrition professionals and clinical psychologists (subject to state regulations).

To learn more about the government changes and Medicare’s new reimbursement policies visit:

1.  Coding information from the American Medical Association (AMA).
2.  A summary of Medicare and Medicaid announcements relating to COVID-19.
3. Information for health care professionals from the Centers for Disease Control and Prevention (CDC).
4.  Detailed information about each state’s data and policy actions in reference to the coronavirus.
5.  General information from CMS about covered services.