Reimbursement for telephone calls

The COVID-19 pandemic has changed how physicians provide patient care in the outpatient setting rapidly and dramatically. During this Public Health Emergency, continuity of treatment of existing patients as well as maintaining a professional relationship with new patients has become difficult. To prevent COVID-19 exposure threats, many geographic areas are under “stay at home” or “shelter in place” orders from state and local governments.

Medicare has recently allowed “broad flexibilities to furnish services using remote communications technology to avoid exposure risks to health care providers, patients, and the community.”

Implementing telemedicine or interactive facilities would assist physicians to provide patients with the required treatment while minimizing the pandemic’s clinical and financial effects. In order to encourage physicians’ adoption of this technology, the relevant coding and billing problems related to the implementation of telemedicine services are addressed below.

New issues require new actions

Public Health Emergency caused due to the COVID-19 pandemic is an opportunity to think out of the box and consider practicing in historically unconventional and alternative ways. The fast introduction of innovative techniques and new ways of delivering treatment is essential to the viability of short-term practice. Overnight or very short-term changes, such as consolidating several practice sites to a single site, have been implemented by many practices. In order to maintain current and future clinical and financial sustainability, it is necessary to integrate virtual services in your practice now.

Changes in Medicare Policy On Telephone Billing

For the period of the COVID-19, Medicare will pay for virtual services given to patients in broader circumstances and with relaxed conditions. These new rates are retroactively effective March 1, 2020. On March 30, 2020, the Department of Health and Human Services (DHHS) Centers for Medicare & Medicaid Services (CMS) published guidelines further expanding access to Medicare telehealth services, so that Medicare patients can receive a broader variety of services from doctors without needing to travel to a health facility. An 1135 waiver has been provided by CMS that allows Medicare to pay for workplace, hospital, and other telemedicine visits around the country, including in patients’ places of residence retroactive to March 1, 2020. Non-Medicare payors are also issuing telemedicine or virtual facilities recommendations. As these are constantly evolving, doctors are advised to check non-Medicare payer policies.

Modality/platform considerations

CMS continues to require a real-time interactive video and audio telecommunications infrastructure for telehealth assessment and management (E/M) visits 99201-99215. The criteria for billing telehealth visit codes, 99201-99215, to Medicare is not met by a telephone call, without the real-time video component. 

The rules mandating a HIPAA-secure platform have been relaxed by CMS and now allow non-HIPAA-secure video chat applications, including Zoom,  Apple FaceTime, Facebook Messenger video chat, Doxy.me, Skype, Google Hangouts video, etc. Public-facing applications such as Twitch, Facebook Live, and TikTok are not allowed. 

Practices must warn patients that privacy threats are potentially raised by any third-party application.

Medicare’s payment rate

Before COVID-19, any telehealth services reported using POS 02 (Telehealth) were paid at a reduced rate (the facility payment rate) by Medicare. However, Medicare would pay the same amount for Virtual services for all dates of service from March 2020 to the end of the current PHE, as it would if the service was delivered in person. Claims submitted with POS 11(Office) will now be paid with Medicare’s non-facility rate which is higher than the payment rate for claims billed with POS 19 (Off Campus-Outpatient Hospital) or POS 22 (On Campus-Outpatient Hospital). 

Medicare’s facility rate will also be applied for any payments made for claims submitted with a POS in a hospital setting (e.g., 22, 19). As the service would have been carried out via telehealth means, any claims submitted with a POS of 02 (Telehealth) will also be paid at Medicare’s facility rate.

A list of covered CPT codes which is referred to as “telehealth visits” by Medicare is provided by CMS. It includes 9921x (established patient visit) and 9920x (new patient visit) codes and requires the use of a real-time audio and video mode. The entire list of codes can be found at https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.

Medicare also reimburses all virtual check-in and e-visits (digital E/M services) services and now during the PHE also pays for telephone calls (99441-99443, 98966-98968). E-visits, virtual check-ins, and phone calls are not considered by CMS to be telehealth facilities.

Telephone calls (99441-99443, 98966-98968)

The CPT codes (99441-99443, 98966-98968) for telephone calls were previously not covered and not payable by Medicare. However, because of the COVID-19 pandemic, telephone E/M facilities are now payable by Medicare for new and existing patients. Although the CPT specifies that these codes are for existing patients, Medicare now allows payment even for new patients for telephone only E/M codes. CMS has also recently suggested, in addition to updated prices, that it would require providers to use modifier 95 while billing for telephone calls.

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