1. Telehealth
Reimbursement
1. The Challenges
2. Coding - CPT, HCPCS, POS,
Modifiers
3. Documentation
4. Reaping the Rewards

2. Your Challenges
1. No payer consistency in rules: 1) which codes, 2) place of service, 3) use
of modifier
2. Payer policy changing “overnight”
3. Multiple sets of lists of allowed codes via telehealth
4. Confusion between office visits via telehealth, online digital E/M,
telephone visits, and Communication Technology Based Services (CTBS)
5. Check with your malpractice carrier for their advice: a) malpractice
coverage; b) risks specific to telemedicine; c) documentation; and/or d)
informed consent needs for modification for virtual services
2

3. Telehealth vs. Telemedicine
The terms Telehealth and Telemedicine are often used interchangeably by many,
BUT there is a difference in what these terms mean and apply to:
 Telemedicine = the practice of medicine using technology to deliver care at a distance. A
physician is in one locations using a telecommunications infrastructure to deliver care to a
patient at a distant site.
 Telehealth = broadly refers to electronic and telecommunications technologies and services
used to provide non-clinical care and services at-a-distance
Medicare has yet a third type of service they cover: - Communication Technology-Based Services
(CTBS) – it is important for you to understand what services fall under each of these categories and
how to bill for each!
Commercial payers have their own definitions as well – know what they are!!!!

4. Telemedicine today (including Medicare)
 Practitioner is in their office (or other site), patient is at home
 Practitioner uses CPT or HCPCS codes to report service
 For Medicare, use place of service where you usually provide
this service (i.e. Office, hospital, SNF, LCF); others may use 02
 Identify usual CPT code with modifier -95
4

5. Medicare Telehealth today
Service Codes
Office visits 99201 – 99215
Smoking cessation 99406 , 99407
Transitional care management 99495, 99496
Advanced care planning 99497, 99498
Prolonged services 99354, - 99357
Prolonged preventive services G0513, G0514
Initial and subsequent wellness visits G0438, G0439
Psychiatric diagnostic interview 90791, 90792
Individual psychotherapy 90832 – 90838
Interactive complexity (psychiatry add-on) 90785
Psychotherapy for crisis 90839, 90840
5
**Medicare added 85 additional codes to this list of 101 codes with the interim rule,
released March 2020, which include some therapy services; they are designated
temporary for PHE COVID 19 Pandemic

6. Medicare Telehealth today
Other services are covered:
 Also, ED, inpatient consults and skilled nursing facility services, with
HCPCS codes
 Diabetes self management, kidney disease education, nutrition
therapy
 ERSD services
 Psychiatry services
 Some PT/OT services
 Some screening HCPCS codes
6

7. Level of E/M Service
 If counseling dominates the visit, use time
 Count only practitioner time
 For established patients, 2 of 3 of history, exam and
MDM
 New patients require all three components, if not time
based
 Exam can be observational, but will limit level
7

8.  When CMS released the rule on 3/30/2020, they
added a section (W) titled, “ Level Selection for
Office/Outpatient E/M Visits when Furnished Via
Medicare Telehealth.”
 The brief section starts by discussing the upcoming
changes in 2021 for codes 99202 – 99215, in which a
practitioner can select a level of service based on
total time for the day or MDM. The time spent
includes non-face-to-face time that the
practitioner spends and does not need to be
dominated by counseling.
 CMS is using different time thresholds for selecting
99201 – 99215 based on time during the public
health emergency.
 Specifically, they are removing any requirement for
history and/or physical exam during this time of
emergency.
A full explanation of the
new time rules will be
posted on the ACCMA
COVID 19 Resource
Page. It is important to
understand the new
temporary rules for
documenting and using
time during this PHE.
8

9. Billing the Telemedicine Office Visit
 Place of Service (POS) = 11; field 24B CMS 1500 form
 Location = Your Office Location; field 32 CMS 1500 form
 Know requirements for consent
 California BPC Section 2290.5 is clear:
“ . . . The health care provider initiating the use of telehealth shall inform the
patient about the use telehealth and obtain verbal or written consent from the
patient for the use of telehealth and obtain verbal or written consent from the
patient for the use of telehealth as an acceptable mode of delivering health
care services and public health. The consent shall be documented.”
Can be verbal or written. There is no specific guidance for verbal consent.
Suggestion: “The patient consented to telehealth medical services being
provided virtually via: XXXXX”
9

10. Telemedicine and Commercial Payers
1. CPT Appendix P has a list of services CPT considers can be performed
via telemedicine
2. Not exactly like the CMS list . . . Your commercial payers can make
their own lists
3. Need to check every payer’s website; read their emails
1. Make a list of your payers
2. Develop a grid
3. Check often
10

11. Commercial Grid Example
11
Payor Paying for
Telehealth
Eff. Date POS Modifier Cost
Sharing
More Info
Medicare Yes 3/6/2020 Usual
POS
95 Provider may
waive
https://www.cms.gov/newsroom/f
act-sheets/medicare-
telemedicine-health-care-
provider-fact-sheet
Aetna Yes 3/17/2020 02 95 or
GT
No cost
sharing if in-
network
https://www.aetna.com/health-
care-professionals/provider-
education-manuals/covid-
faq.html#acc_link_content_sectio
n_responsivegrid_copy_responsi
vegrid_accordion_12
Cigna Yes 4/1/2020 Usual
POS
95 or
GT
Cost sharing
for some
services
https://static.cigna.com/spa///chcp
/assets/Cigna-COVID-19-Billing-
Guidance-for-Providers-3-18-pdf
UHC Yes 3/17/2020 02,
but
not
req.
95 or
GT
No cost
sharing
https://www.uhcprovider.com/
en/resource-
library/news//////provider-
telehealth-policies.html
WC – CA Yes 4/15/2020 Usual
POS
95 No www.dir.ca.gov/dwc
This is just an example and good as of the date accessed; please check back with each plan for updates.

12. Virtual Check-In
 The Service: A brief (5-10min.) check in with your practitioner via
telephone or other telecommunications device to decide whether an
office visit or other service is needed.
 HCPCS Codes
 G2012 (visit)
 Patient / Provider Relationship – For established patients
12

13. Remember This About Virtual
Check-In
 These services are NOT considered telehealth services
 Bill with POS 11 (office)
 These aren’t office visits via audio/video, but are more complex and
convoluted to do and document
 Use E/M visit codes if you have the capability to do so!
13

14. Remote Monitoring
 The Service: A remote evaluation of recorded video and/or images
submitted by an established patient, including interpretation with follow-up
with the patient within 24 business hours
 HCPCS Code – G2010
 Patient / Provider Relationship – For established patients
14

15. E-Visits
 The Service: A communication between a patient and their provider
through an online patient portal (email)
 HCPCS/CPT Codes
 99421
 99422
 99423
 G2061
 G2062
 G2063
 Patient / Provider Relationship – For established patients
15

16. Remember this about E-Visits & Remote
Monitoring
 These codes have specific requirements
 Time-based (e-visits)
 Add up time over a 7-day period
 No visit 7 days prior
 None of these codes pay very well
 Use E/M visit codes if you have the capability to do so!
16

17. Prepare to
Reap the
Rewards
1. Assess your
appointment
scheduling for
telemedicine visits
2. Obtain consent
3. Collect
copayments
4. Plan the visits
17

18. Use these tips to assure a Positive Telehealth
Experience (for both you and your patient)
18
Check your Wi-Fi speed – ensure it is of a good quality for one on one
conferences. Avoid downloading files while on the video conferenceCheck
Set up your camera to be eye level or above; your upper body should be
visible (NO talking heads)Set up
Don’t have a blank wall behind you – it is visually unpleasing. A painting,
bookcase, etc. is more attractive & pleasingDon’t have
Try to stay still during the call; nothing is more distracting than a head that is
bobbing and weavingTry

19. More tips for
a Positive
Telehealth
Experience
19
Make sure your computer microphone and
speakers work well; use a headset if
needed
Recognize there may be a lag on audio –
when your patient stops talking count to
before speaking so as not to interrupt your
patient
Practice looking at the camera so you will
be making eye contract with your patient –
however keep scanning at the screen to
observe your patient’s facial expressions
Have these virtual visits in a quite place, to
simulate an exam room; dress
professionally as if you were in the office
(even if you are not)

20. QUESTIONS?
Mary Jean Sage
The Sage Associates
mjsage@thesageassociates.com
www.thesageassociates.com
Tel: (805) 904-6311