Billing & Coding Telehealth Services

Under the New COVID-19 Waiver Programs

Agenda

Telehealth Conditions for Payment Billing, Payment, and Documentation Requirements Coding for COVID-19 Telehealth Examples Valuable References

Telehealth vs. Telemedicine

Telehealth refers to a broad range of technologies and services to provide patient care and improve the healthcare delivery system as a whole. Telehealth is different from telemedicine because it refers to a broader scope of remote healthcare services than telemedicine.

Telemedicine is a subset of telehealth that refers solely to the provision of health care services and education over a distance, through the use of telecommunications technology. Telemedicine involves the use of electronic communications and software to provide clinical services to patients without an in-person visit.

Telemedicine technology is frequently used for follow-up visits, management of chronic conditions, medication management, specialist consultation and a host of other clinical services that can be provided remotely via secure video and audio connections.

Telehealth Technology Requirements

Communication hardware can include but is not limited to:

Telephone, Computer, IPad, cell phone

Any non-public facing application (e.g. not social media) or

software that is available to communicate with patients.

Compliance with HIPAA waived- no penalties

Telehealth can be provided for COVID-19 or any other

condition

HHS Telehealth Guidance

Telehealth Technology Requirements

• Facetime, Skype, Zoom etc. AREacceptable

• HIPAA compliant examples include but are not limited to-

Zoom for HealthcareDoxy.meSkype for BusinessUpdoxVseeGoToMeetingAmazon ChimeGoogle G Suites Hangout

*NOT acceptable- public facing applications such as Tik Tok, Facebook Live, and Twitch

Originating Site (Patient’s Location)

Originating Site: Medicare Fee For Service While they must generally travel to or be located in certain types of

originating sites such as a physician’s office, skilled nursing facility or hospital for the visit, effective for services starting March 6, 2020 and for the duration of the COVID-19 Public Health Emergency, Medicare will make payment for Medicare telehealth services furnished to beneficiaries in any healthcare facility and in their home.

Where the beneficiary receives those services is known as the “eligible originating site.” The beneficiary’s home is generally not an eligible originating site, but under the new 1135 waiver, this will be waived during the emergency. This will now allow telehealth services to be provided in all settings –including at a patient’s home. FAQ31720

Originating Site: Medicare RHC

• An originating site is where an eligible Medicare beneficiary is located during the telehealth service.

• RHCs that serve as an originating site for telehealth services are paid an originating site facility fee.

• Charges for the originating site facility fee may be included on a claim.

Source: RHC MLN Fact Sheet

Originating Site: Illinois MedicaidTo protect the public health in connection with the present public health emergency, the Department will reimburse medically necessary and clinically appropriate telehealth services with dates of service on or after March 9, 2020 until the public health emergency no longer exists, that meet the following requirements:

To be eligible for reimbursement, the telehealth service must be delivered using:1. an “interactive telecommunication system” or “telecommunication system” as described in 89 Ill. Admin. Code Section 140.403(a), or;2. a communication system where information exchanged between the physician or other qualified health care practitioner and the patient during the course of the synchronous telehealth service is of an amount and nature that would be sufficient to meet the key components and requirements of the same service when rendered via face-to-face interaction.

• Any site that allows for the patient to use a communication or technology system as defined above may be an originating site, including a patient’s place of residence located within the state of Illinois or other temporary location within or outside the state of Illinois.

• A physician or other licensed health care professional is not required to be present at all times with the patient at the originating site.

• An originating site will be eligible for a facility fee when it is a certified eligible facility or provider organization that acts as the location of the patient at the time a telehealth service is rendered, including but not limited to:

• substance abuse centers licensed by the Department of Human Services' Division of Substance Use Prevention and Recovery;

• Supportive Living Program providers;• Hospice providers;• Community Integrated Living Arrangement

(CILA) providers; and• providers who receive reimbursement for a

patient's room and board, including nursing facilities and Intermediate Care Facilities for the Developmentally Disabled

Originating Site: Illinois Medicaid

Source: Provider Notice 3/20/2020

Distant Site Practitioners-Medicare FFSMust be within practitioner’s scope of practice under state law

• Physician/ Nurse practitioner/ Physician assistant

• Nurse-midwife/ Clinical nurse specialist

• Certified registered nurse anesthetist

• Clinical psychologist

• Clinical social worker

• Registered dietician or nutrition professional

Distant Site: Medicare RHC

• RHCs are not authorized to serve as a distant site for telehealth consultations.

• A distant site is where the practitioner is located during the time of the telehealth service.

Sources: RHC MLN Fact Sheet

Medicare Claims Processing Manual Chapter 9-Section 80-Telehealth Services

• a Practitioner listed in 140.403(b)(1)(B) or (b)(2)(B);

• a Federally Qualified Health Center as defined in Section 1905(l)(2)(B) of the federal Social Security Act;

• a Rural Health Clinic or Encounter Rate Clinic;

• a Licensed Clinical Psychologist (LCP);• A Licensed Clinical Social Worker (LCSW);• an Advanced Practice Registered Nurse

certified in psychiatric and mental health nursing,

• a Local Education Agency (LEA)

• a School Based Health Center as defined in 77 Ill. Adm. Code, 641.10.

• a Physical, Speech, or Occupational therapist as defined in 140.457

• a Dentist

• a Local Health Department

• a Community Health Agency

• a Community Mental Health Center or Behavioral Health Clinic

• a Hospital as defined in 148.25

Distant Site Practitioners-IL MedicaidThe distant site provider is any enrolled provider, operating within their scope of practice, and with the appropriate license or certification. This includes, but is not limited to:

Reimbursement for telehealth services will continue to be made at the same rate paid for face-to-face services provided on-site. The distant site provider and originating site provider eligible for a facility fee must maintain adequate documentation of the telehealth services provided in accordance with the record requirements of section 140.403(d).

Medicare Advantage Payer Guidance

Center for Connected Health Policy Fact Sheet

Private Payer Guidance

Center for Connected Health Policy Fact Sheet

Telehealth Billing & Coding Information

CPT, HCPCS, ICD-10-CM

Telehealth Medicare Originating Site Facility Fee-Separate Part B Payment

• CAH and RHC/FQHC – Payment is separate from cost-based

reimbursement methodology and amount is 80 percent of the originating

site facility fee.

• Hospital Outpatient/Inpatient/Physician Office – Lesser of 80 percent of

actual charge or 80 percent of the originating site facility fee

Medicare Claims Processing Manual Chap. 12, Sec. 190.5

Telehealth Services CPT/HCPCS CodesTelehealth visits

99201-99215 (outpatient visits) (Not RHC)G0425-G0427 (consults, emergency department, and initial inpatient visits)G0406-G0408 (f/u consults in hospitals and SNFs)

Virtual Check-inVia telephone - HCPCS II code G2012Video/images may be sent to a physician -HCPCS II code G2010For RHC, refer to G0071

E-visitsCommunication with patient and provider using a patient portal99421-99423, G2061-G2063

Telehealth Modifiers are only necessary in these situations:GO modifier for diagnosis and treatment of an acute strokeGT modifier is only required when telehealth is billed by a CAH using Method II billing methodology

List of Covered Telehealth Codes

Billing Guidelines – Originating Site Medicare

• HCPCS Code – Q3014

• Place of Service -depends on where the patient is located if billing on a Professional Claim

(1500)

• Revenue Code = 0780

• CAH Method I or II – Type of Bill is 0851

• RHC –Type of Bill is 071X

• FQHC- Type of bill is 077X

Billing Guidelines - Distant Site Medicare

• Place of Service POS – 02

• Type of Bill is 0851 –Method I or II CAH

• CAH Method II- report the actual telehealth professional HCPCS fees using rev codes

096X, 097X, or 098X

• Modifier – GT is required when telehealth is billed by a CAH using Method II billing

methodology

(Medicare Claims Processing Manual, Pub. 100-04, chap. 12, sec. 190.3, 190.6 [trans. 4468,

November 27, 2019])

Virtual Check-Ins (Live -Telephone)

HCPCS code 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.

• Claim type can be 1500 or UB• Place of Service (POS) on a 1500 =22• UB revenue code =0988

Virtual Check-Ins (Images or Video)

HCPCS code G2010: Remote evaluation of recorded video and/or images submitted by an 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 provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment

• Claim type can be 1500 or UB• Place of Service (POS) on a 1500 =22• UB revenue code =0969

Virtual Communications - RHC/FQHCHCPCS code G0071: Payment for communication technology-based services for 5 minutes or more of a virtual (non-face-to-face) communication between an rural health clinic (RHC) or federally qualified health center (FQHC) practitioner and RHC or FQHC patient, or 5 minutes or more of remote evaluation of recorded video and/or images by an RHC or FQHC practitioner, occurring in lieu of an office visit; RHC or FQHC only

• Bill type = 071X (RHC) 077X (FQHC)• UB revenue code = 0969

E -Visits99421: Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5–10 minutes

99422: Online digital evaluation and management service, for an established patient, for up to 7 days cumulative time during the 7 days; 11– 20 minutes

99423: Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 21 or more minutes

• Claim type can be 1500 or UB• POS on a 1500 =22• UB revenue code =0982

Telehealth Documentation RequirementsSame as for any face-to-face patient encounter (history, exam, medical decision-making; with the addition of thefollowing:

• A statement that the service was provided using telemedicine;

• The location of the patient

• The location of the provider and

• The names of all persons participating in the telemedicine service and their role in the encounter

Coding for COVID-19 TestingStarting in April, laboratories performing the test can bill Medicare and other health insurers for services that occurred after February 4, 2020, using one of the newly created HCPCS II codes (U0001 and U0002)

• U0001: CDC-specific test

• U0002 :Laboratories performing non-CDC laboratory tests for COVID-19

• 87635-(New CPT code) (“Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique

Independent RHC will report the lab service using the CMS-1500 while provider based will report rev code 0300 and capture on CMS-1450 (“UB”)

Pricing information:https://www.cms.gov/files/document/mac-covid-19-test-pricing.pdf

ICD-10-CM Coding Guidance• For pneumonia due to COVID-19, assign J12.89 (other viral pneumonia and B97.29 (other coronavirus

as cause of disease)

• For acute bronchitis due to COVID-19, assign J22 (unspecified acute lower respiratory infection) and

B97.29 (other coronavirus as cause of disease)

• For ARDS (acute respiratory distress syndrome) due to COVID-19, report J80 (acute respiratory

distress syndrome) and B97.29 (other coronavirus as cause of disease)

• For possible exposure to COVID-19 with the disease ruled out, report Z03.818 (Encounter for

observation for suspected exposure to other biological agents ruled out).

• For actual exposure to COVID-19, report Z20.828 (Contact with and (suspected) exposure to other

viral communicable diseases.) ICD-10-CM Interim Coding Advice COVID-19

ICD-10-CM Coding GuidanceSigns and symptoms

• For patients presenting with any signs/symptoms (such as fever, etc.) and where a

definitive diagnosis has not been established, assign the appropriate code(s) for each

of the presenting signs and symptoms such as:

• R05 Cough

• R06.02 Shortness of breath

• R50.9 Fever, unspecified

ICD-10-CM Interim Coding Advice COVID-19

Telehealth Example

Telehealth ExampleDr. Smith, PCP is located in a non-RHC physician’s office.

• Mrs. Lee was triaged over the phone by Trudi, RN for Dr. Smith, with complaints of fever, shortness of breath, and fatigue. Nurse Trudi received a verbal consent from Mrs. Lee to a telehealth visit and then asked Dr. Smith to evaluate Mrs. Lee viatelehealth.

• Mrs. Lee presented from a verified originating site (her home) via FaceTime. Dr. Smith conducted an evaluation with Trudi, RN present in the room and determined that no further testing was required at this time.

• Dr. Smith directed Mrs. Lee to self-quarantine for 14 days and to contact the office immediately if her symptoms worsened.

• How should Dr. Smith code his claim to Medicare?

Telehealth Example• Dr. Smith documented the service provided as if he saw Mrs. Lee in person, and

included a statement that the service was provided using telemedicine; the location of Mrs. Lee (her home) Dr. Smith’s location (his office); and the names of all persons participating in the telemedicine service (Trudi) and her role in the encounter (RN).

• Dr. Smith billed the service provided as if he saw Mrs. Lee in person, using the appropriate CPT codes, while appending POS code “02.”

• Using this POS indicates it was rendered via telehealth using an interactive audio and video telecommunications system.

• He sent the claim to the MAC that supports the state he was physically located when he rendered the service (his office).

Sample Tele-Medicine Mobile Office Device

Center for Connected Health Policy

• CCHP Telehealth Coverage Policies in the Time of COVID-19 3/23/2020

• CCHP Billing for Telehealth Encounters Intro Guide

Illinois HFS/Medicaid

• Illinois HFS Provider Notice 3/20/2020 Telehealth Service Expansion Prompted by COVID-19

• Section 1135 Wavier Flexibilities – Illinois Coronavirus Disease 2019

CMS• CMS Coronavirus (COVID-19) Partner Toolkit• CMS COVID-10 Emergency Declaration

Health Care Providers Fact Sheet 3/13/2020• CMS Medicare Coverage and Payment

Related to COVID-19 Medicare 3/5/2020• CMS Medicare Telehealth FAQs 3/17/2020• CMS Medicare Telemedicine Health Care

Provider Fact Sheet 3/17/2020• CMS MLN Booklet Telehealth Service March

2020• CMS Virtual Communication Services in

RHCs and FQHCs Frequently Asked Questions December 2018

References

Ongoing Telehealth Changes

• Waiting for Congress to approve statutory requirements for RHCs and

FQHCs to serve as distance sites for telehealth visits/encounters.

• Waiting for a Medicaid Managed Care Organization (MCO) billing guide for

telehealth (this week).

• Unsure of the end date for the waiver telehealth.

• Consultants are wonderful and helpful – verify their sources as there is a

great deal of misinformation.

Questions/Answers