Physician practices scrambled to offer telehealth services to patients during the first days of the COVID-19 public health emergency. At the same time, governmental and commercial payers issued temporary guidance that relaxed or changed some requirements for eligible telehealth services and how these services should be coded. Now that the dust has settled, what should providers be aware of as payers begin to review telehealth claims post-payment?
Physicians should meet with the coding and billing personnel to answer some key questions about their telehealth services to assess whether claims may need to be re-filed or if there is a risk for repayments due to payers for non-covered services. These questions should be answered for your practice’s major payers. If your practice operates in multiple states, you should be aware that differing state laws and guidance may result in different coding requirements for similar services provided to the same payer types.
How are we tracking insurers’ effective dates for COVID-19 temporary guidance?
Tracking different insurers’ requirements is a time-consuming, yet critical task. For commercial insurance, America’s Health Insurance Plans (AHIP) has published a running list of COVID-19 related actions by its member insurance plans. The Centers for Medicare and Medicaid Services (CMS) has published a variety of information related to telehealth services on its COVID-19 page. In Kentucky, the Cabinet for Health and Family Services has issued actions and guidance related to Telehealth that was last updated on 3/30/2020.
What services are covered?
Payers may cover various visit types and telehealth services. For reference, CMS has provided a list of CPT codes which can be provided via telehealth, along with whether these services are reimbursable via audio-only technology.
Are nurse practitioners or physician assistants eligible to provide telehealth services?
Practice managers should be carefully tracking which payers allow for NPs, PAs and other advanced practitioners to render telehealth services. After creating a list of payers which allow it, practice managers should review NP/PA billing to determine if any would not be eligible.
Should we use telehealth or office visit codes?
Certain payers require providers to use telehealth-specific CPT codes, while others—namely Medicare—allow for a fairly broad range of evaluation and management service codes to be performed and billed via telehealth.
What place of service code should be used?
Most commercial insurers have instructed providers to use place of service code ‘02’ for telehealth visits. Medicare, however, has instructed providers to use the place of service code that would have been used if the visit had been face-to-face. For physician offices, this will be place of service code ’11.’ Physician practice personnel should monitor claims where the primary and secondary insurers have differing place of service codes.
What modifiers are necessary?
As with the place of service code question, modifier usage can conflict among payers. Notably, CMS has instructed providers to append modifier ‘95’ to telehealth claims during the public health emergency to denote that the service was provided through telehealth. Since most other insurers have providers use the telehealth-specific place of service code ’02,’ such a modifier is not needed.
How are we capturing what technology was used to provide the telehealth visit?
Providers should document what technology is being used to conduct the visit. Is it an already established and approved telehealth service? Is it a private teleconferencing solution such as Zoom? Was the visit conducting entirely over the phone? Having this documentation on hand will help physician practices support billed telehealth charges, in the event they are ever reviewed by a payer.
How are we tracking the amount of time spent on the encounter?
Certain telemedicine codes are based on the amount of time the provider spends with the patient—namely codes 99441-99443. Providing a means for capturing the amount of time spent will save headaches down the road if payers ever ask for support these codes.
Physicians and their coding and billing staff should ask these questions and track responses. Given how quickly things changed due to the COVID-19 public health emergency and the divergent requirements of payers—you should expect some errors. With sound practices in documenting telehealth services and regular reviews—these errors can be caught and corrected before a payer-initiated review.
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