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COVID-19 has left providers scrambling for revenue sources. Recently, major insurance carriers - including Cigna and Aetna - have announced temporary expansion of telehealth (i.e. telemedicine) coverage. Since these announcements were made, we've received many questions about how to bill for telemedicine. The information below compiles our research on telemedicine (TLM) billing. Bookmark this page and check back frequently - we will continue to update it throughout the crisis.
Table of Contents
How to Provide Telemedicine Visits
References
- State Stay-at-Home and Shelter-in-Place Orders
- COVID-19 Virtual Town Hall for Acupuncturists: Click "Watch the replay here". You may need to provide your name and email address to view this presentation.
- AMA COVID-19 Resource Center
- AMA tips for keeping your practice in business during COVID-19
- AAC Coding, Documenting, and Compliance of Telehealth
- Coding Intel: Telemedicine Billing
- Coding Intel: Telemedine and COVID-19 FAQ (updated frequently)
- Medicare Telehealth FAQ (PDF)
- Medicare Learning Network Telehealth Services Booklet (PDF)
Carrier Announcements (with carrier-specific requirements)
- Aetna
- Blue Cross Blue Shield
- Anthem BCBS (all states)
- Carefirst BCBS of Maryland (click "Specialists"). Refer to this document for modifier code info.
- Regence BCBS (all states) - accepts standard E/M codes w/ POS 11 and modifier GT (omit modifier 25)
- Regence FEP (all states) - accepts CPT codes 99421-3, 98970-2, 99441-3, 98966-8, G0406-8, G0425-7, G2010, G2012, G2061-3, Q3014 (not all may apply for LAcs); use POS 02 and modifier GT; omit modifier 25.
- Cigna - accepts standard E/M codes w/ POS 11 and GQ, GT or 95 modifier.
- Johns Hopkins EHP - accepts standard E/M codes w/ POS 02. (Policy Document available here)
- Moda
- Optum VA Community Care Network
- UHC - accepts standard E/M codes w/ POS 11 and modifier GT; omit modifier 25. (Additional Info)
CPT Coding
What we have learned is that there is no universal coding standard for telemedicine. Coding requirements vary from one carrier to the next.
That being the case, in order to determine each carrier's requirements, we must research telemedicine benefits. Our standard intake form has been slightly modified to accommodate TLM benefit research.
CPT Codes 99421-99423 and G2061-G2063
CPT codes 99421-99423 are for telemedicine visits using an encrypted video service (click here for our recommendations).
- 99421: 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: 11-20 minutes
- 99423: 21 or more minutes
"CPT codes 99421-99423 are reserved for physicians and other healthcare practitioners that can directly bill Medicare E/M codes. Acknowledging that there are non-physician healthcare practitioners who are unable to bill Medicare but that will likely perform these e-Visits, CMS created HCPCS codes G2061, G2062, and G2063 for non-physician practitioners who are unable to bill E/M services. CMS specifically stated in the rule that audiologists and speech language pathologists are ineligible to bill for HCPCS codes G2061-G2063 because the codes fall outside their benefit category." (per Nixon Law Group)
"Here’s a bit more about these services:
- Patients must initiate them. Most often, the communication will come through a secure patient portal, though secure email and other HIPAA-compliant digital applications are also possible venues, says Elhoms. The key here is ‘patient initiated.’ Patients won’t initiate the services if they don’t know a practice offers them. Elhoms recommends sending out letters to patients, posting appropriate signage, designing a one-page flier, offering reminders during the scheduling and check-in process. Engaging physicians to include these new services in their after-care instructions is also important as is leveraging social media and posting educational videos about the e-visit option.
- Physicians must perform an actual E/M service. This means they must evaluate, assess, and manage the patient—not simply communicate test results or schedule appointments.
- Patients must be established. However, the presenting problem may be new to the physician.
- They’re cumulative. This means they’re rendered over a seven-day period starting with the he cumulative service also includes review of the patient’s records or pertinent data, interaction with other clinical staff regarding the patient’s problem, development of management plans, and subsequent communication with the patient via online, telephone, email, or other digitally-supported communication. Note that clinical staff time does not count toward the cumulative total—only the physician’s time counts.
- There are other important restrictions. For example, physicians can’t report these online digital EM services when a separately-reported E/M service occurs within seven days of the initiation of the online digital E/M service. This includes E/M visits and procedures provided through synchronous telemedicine visits using interactive audio and video telecommunication equipment. Likewise, if a patient initiates an online digital inquiry for the same or a related problem within seven days of a previous E/M service, the physician cannot report the online digital service. They can report the online digital service for a new and unrelated problem.
- Don’t confuse them with other virtual care codes. This includes G2010 (which requires providers to review photos or video information submitted by the patient to determine whether a visit is required) and G2012 (which requires a telephone or video check-in with the patient to determine whether a visit is required). The new codes don’t require the review of photos or videos, says Elhoms." (per Lisa Aramo of at SolutionReach)
"Now what are the codes? Okay. So for online digital evaluation of a patient, which means you're going to do some type of virtual visit, the first code is 99421, that is online digital evaluation management service for an established patient for up to seven days of cumulative time during a seven day period, for five to 10 minutes. So in other words, it's the entire time up to a seven day period. So this might be several communications with a patient within seven days, and the time would be cumulative. But it certainly could be just for one, if it's only one within that time. You'll notice the codes are relatively simple, in that one is for five to 10 minutes, one is for 11 to 20 minutes, and one is for 21 minutes or more. So simply put, once you get over 21 minutes, then it's just a 99423, and this would be again, the accumulative time for each patient. And again, it's online, meaning through some type of virtual platform. These are patient-initiated services for the assessment and management of the patient. They're not intended for non-evaluative communication for test results." (per Sam Collins of the American Acupuncture Council)
"Report these services once during a 7-day period, for the cumulative time." (per Coding Intel)
"The seven-day period begins with the physician’s or other qualified health care professional’s (QHP) initial, personal review of the patient-generated inquiry. Physician’s or other QHP’s cumulative service time includes review of the initial inquiry, review of patient records or data pertinent to assessment of the patient’s problem, personal physician or other QHP interaction with clinical staff focused on the patient’s problem, development of management plans, including physician or other QHP generation of prescriptions or ordering of tests, and subsequent communication with the patient through online, telephone, email, or other digitally supported communication, which does not otherwise represent separately reported E/M service." (CPT Professional Edition, 2020. AMA, Chicago, p. 68.)
CPT Codes 99441-99443
CPT codes 99441-99443 are for telemedicine visits by phone.
- 99441: Telephone evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes
- 99442: 11-20 minutes
- 99443: 21-30 minutes
CPT Code 99444
Starting in 2020, CPT Code 99444 (an online E/M service by a physician or other qualified health care professional) has been discontinued. It was replaced by 99241-3.
However, some carriers may still use and require this code.
Modifier Codes GQ, GT, and 95
Based on our current research, GT seems to be the only relevant modifier code for LAcs. billing telemedicine.
Carriers that require CPT codes other than 99241-3 may require alternate modifier codes.
Standard Established Patient E/M Visit Codes (99211-5)
Tentatively, some carriers (notably, Aetna) may accept the standard established patient E/M codes included on our superbill if used with POS 02.
Telemedicine visits are not an option for new patients.
How To Provide Telemedicine Visits
These are the solutions we recommend. We cannot recommend Skype, Facetime, or any other service that is not HIPAA-compliant. (ChARM has videoconferencing functionality, but their website doesn't indicate whether it is HIPAA-compliant. If you can confirm, let us know!)
- Doxy.me is a free solution for telemedicine visits. It complies with global security standards, including (but not limited to) HIPAA.
- Jane App is a practice management software. They recently added a videoconferencing feature in response to COVID-19.
- Unified Practice is another practice management / EHR (electronic health records) solution that recently added videoconferencing features in response to COVID-19.
