CMS has expanded Medicare telehealth benefits on a temporary and emergency basis pursuant to the Coronavirus Preparedness and Response Supplemental Appropriations Act. Starting March 6, 2020, Medicare will pay for office, hospital, and other visits furnished via telehealth provided by doctors, nurse practitioners, clinical psychologists, and licensed clinical social workers. The HHS Office of Inspector General (OIG) is also allowing healthcare providers to reduce or waive cost-sharing for telehealth visits. Previously, telehealth benefits under Medicare were limited to when the patient was located in a designated rural area and went to a clinic, hospital, or certain other types of medical facilities for the service.
There are three categories of services that will be reimbursed by Medicare. The first category is telehealth. Telehealth visits are considered the same as an in-person visit and are paid at the same rate. Physicians, nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologists, clinical social workers, registered dietitians, and nutrition professionals may provide telehealth services if it is within the scope of practice of the professional as determined by state law. Medicare will pay for telehealth services furnished to a patient in a healthcare facility or in the patient’s home. Telehealth services are billed under HCPCS/CPT codes: 99201-99215 (office of other outpatient visits); G0425 –G0427 (telehealth consultations emergency department or initial inpatient); G0406-G0408 (follow-up inpatient telehealth consultations furnished to beneficiaries in hospitals or SNFs).
The second category is virtual check-ins, which involve a brief communication between patient and practitioners via synchronous discussion over a telephone or exchange of information through video or image. Virtual check-ins are only for patients with an established (or existing) relationship with a practitioner where the communication is not related to a medical visit within the previous 7 days and does not lead to a medical visit within the next 24 hours (or soonest appointment available). The patient must consent to receive virtual check-in services. However, unlike telehealth services, the Medicare coinsurance and deductible would apply. Virtual check-in services provided through telephone, audio/video, secure text messaging, email, or use of a patient portal are billed under HCPCS code G2012. 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 can be billed as HCPCS code G2010.
E-Visits are the third category which are patient-initiated online evaluation and management conducted via a patient portal. E-Visit services may be billed using CPT codes 99421-99423 and HCPCS codes G2061-G2063, as applicable. The patient must verbally consent to receive virtual check-in services. The Medicare coinsurance and deductible would apply to these services.
At this time, telehealth claims will not require the “DR” condition code or “CR” modifier. However, there are three scenarios where modifiers are required on Medicare telehealth claims. First, when the telehealth service is furnished via asynchronous (store and forward) technology as part of a federal telemedicine demonstration project in Alaska and Hawaii, the GQ modifier is required. Second, when a telehealth service is billed under CAH Method II, the GT modifier is required. Third, when telehealth service is furnished for purposes of diagnosis and treatment of an acute stroke, the G0 modifier is required.
The expansion of telehealth benefits under Medicare is being made by CMS on a temporary and emergency basis under the 1135 waiver authority. Providers will need to be mindful of the termination of these expanded benefits at the conclusion of the COVID-19 nationwide public health emergency.