Updates for Telehealth, more

We have been sending e-mails out through our various contact lists and connections over the past couple of weeks and concluded it best to post any updates to one, single location from which everyone can see.  The one constant during this PHE has been change.  Practices have been working hard to keep up with new information impacting covered patient services, modifiers, etc. coming out almost daily.  Clearly, if you are working off information updated last week, you might be out of date already. 

So here is our attempt to get up to date (as of today, anyway).  As always, what we provide is intended to inform and educate but we do not pretend to be experts in all areas of healthcare.  The most up-to-date information and posted changes will come from your individual payers as they post their specific plan update information, so please ensure you are checking with them frequently.  Here is a chronology of CMS updates and the associated references:
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17 April:  Telehealth coverage flexibilities now include RHCs and FQHCs for the duration of the COVID-19 PHE.  Reminder, telehealth services require both audio and video.  The entire release notice is here.  RHCs will be paid at their all-inclusive rate (AIR), and FQHCs will be paid based on the FQHC Prospective Payment System (PPS) rate.  Medicare will also be paying RHCs and FQHCs for the portal codes 99421-99423 the same way they pay physician offices (7 days cumulative time) as well as the G2012 and G2010.
14 April clarification on telehealth added below with the 6 April information.
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10 April:  New and revised immunology codes provided

• 86318 (REVISED):    Immunoassay for infectious agent antibody(ies), qualitative or semiquantitative, single step method (eg, reagent strip);
• 86328 (NEW):   severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19])        (For severe acute respiratory syndrome coronavirus 2 [SARS-CoV-2] [Coronavirus disease {COVID-19}] antibody testing using multiple-step method, use 86769)
• 86769 (NEW):   Antibody; severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19])

6 & 7 April: Coding for telehealth
“To modifier or not to modifier?”, that was the question (among others). 
Much confusion arose over how to properly code E&M services, POS, modifier use, etc. during the PHE.  Well, CMS has spoken on this matter one more time with the information updated to the Federal Register this month as well as during the recording they posted on 7 April.

For PART B Medicare patients, you CANNOT bill face-to-face E&M codes for any encounter in which the provider – patient interaction does not utilize audio AND video.  Some PART C Medicare Advantage plans have different guidelines – BE SURE TO FOLLOW WHAT THE PAYER STATES.  If you want their money, follow their rules.  Medicare PART B requires live audio-video interaction with the billing provider to legally bill the code (not with the MA).  Some examples to help illustrate the latest take:
Office-based MD/DO/NP/PA not doing nursing home, hospital work, etc.:

• Office visits 99201-99215 (REQUIRES LIVE AUDIO AND VIDEO)
• POS:  11
• Modifier 95
• Does not matter where patient is; does not matter where provider is

Office-based MD/DO/NP/PA doing nursing home, hospital work, etc. use POS and appropriate E&M code for patient location:

• POS 11 – Office Visits for PTs at home, Modifier 95
• POS 21 – Hospital codes for PTs at hospital, Modifier 95
• POS 31 – SNF codes for PTs in SNF, Modifier 95

Home visitation MD/DO/NP/PA (audio-video visits):

• Home Visit codes 99341-99349
• POS: 12
• Modifier 95

Reminder:  use MDM or time when billing E&M via telehealth.  According to the 6 April posting to the Federal Register, CMS stated they are maintaining the current rules for MDM.  Time, however, ended up being a slightly different outcome: Clarified 14 April, use either CPT time or Federal Register time.  Please note that this only applies to telehealth performed during the COVID-19 PHE.  If seeing a patient in office, and billing for time only if more than half the visit is spent counseling and / or care coordination, the normal CPT times are to be used.  Use of time or MDM alone for in-office visits doesn’t go into effect until 2021… maybe.

2 April:  Still more updates coming out from CMS.  I will be sending these with the hope that you will also share with all the HCPs and offices you work with, colleagues, and friends that can further share the info and (hopefully) have a positive influence on patient care in this challenging time.
Medicare clarified guidance for E/M Telehealth documentation requirements:  need EITHER Time or MDM for E/M level.  Telehealth involves synchronized video and audio interaction between the provider and patient.  Only provider time counts.  As previously reported, the Tele-Health originating site rules were suspended 17 March 2020, effective back to 6 March 2020.  That means the patient’s home can be the originating site during the emergency period.  This should be finalized in the CFR on 6 April, but the draft is out.
Yes, patients can communicate from their home to the provider at a ‘distant site’.  Requirement for both audio AND video remains; however, available applications temporarily include non-HIPAA compliant tools Skype and Facetime.  We recommend still using a HIPAA-compliant app such as Zoom that also allows for easy recording and downloading and clearly documenting the consent in the recording and the note.  Several EMRs have this functionality via their portal or an add-on, as well. 
Additionally, all Medicare beneficiaries can use telehealth services for common visits and preventive screenings – the rural area requirement is also waived. 
Effective 31 March, add 2 new HCPC codes for specimen collection:
·         G2023:  Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), any specimen source
·         G2024:  Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), from an individual in a skilled nursing facility or by a laboratory on behalf of a home health agency, any specimen source
These codes indicate "any source" so don't restrict these only to the nasal swabs.   These are only for trained personnel and not for any patient self-tests.