Billing for Digital and Telehealth Services

The Centers for Medicare & Medicaid Services (CMS) issued the 2023 Physician Fee Schedule (PFS) Final Rule on November 1, 2022. This Final Rule for telehealth and digital service providers includes significant changes, stating new codes that will anticipate and facilitate future growth in these areas. However, medical billers and coders require immediate answers to their digital and telehealth billing services questions. Which codes are to be used, and for what services? How do digital and telehealth services get reimbursed? And many more!!

Let’s begin the journey by knowing about the CPT codes to be used for digital and telehealth services:

CPT Codes:

• Online Digital E/M Services

These are the codes used by clinicians who may independently bill online digital evaluation and management (E/M) services in their scope of practice. They are “messaging” codes, not video, telephone, or in-person services meant for E/M services of a type to be done face-to-face through a HIPAA-compliant secure platform. These CPT codes account for up to 7 days of cumulative time during the seven days for an established patient for an interval of:

99421: 5 – 10 minutes

99422: 11 – 20 minutes

99423: 21 or more minutes

Points to Remember:

1. CMS requires verbal consent.
2. The patient requests the service with an inquiry via the portal.
3. The service is recorded in the patient’s medical record.
4. If the patient received an E/M service within the last seven days, these codes should not be used for communication about that problem.
5. These codes may be billed if the inquiry concerns a new problem (not one addressed by the E/M service in the previous 7 days).
6. If a face-to-face E/M service occurs within seven days of the initiation of the online service, the time of the decision-making complexity or online service may be used to select the E/M service. However, this service may not be billed.
7. During the global period, surgeons may not bill for this.
8. A HIPAA-compliant platform, such as a secure email, an electronic health record portal, or other digital applications, must be used to deliver the digital service.
9. These services may only be reported once every seven days.
10. Clinical staff time is excluded.
11. Don’t include time for any other separately reported services, such as INR monitoring, care management, or remote monitoring.
12. Online Digital with no billing for E/M Services

These are the codes used by clinicians who are qualified non-physician health care professionals and don’t have evaluation and management (E/M) services in their scope of practice. These codes don’t have RVUs assigned to them and have a status indicator of invalid in the Medicare fee schedule for online digital assessment and management services. These CPT codes account for up to 7 days of cumulative time during the seven days for an established patient for an interval of:

98970: 5 – 10 minutes

98971: 11 – 20 minutes

98972: 21 or more minutes

Point to Remember:

As of December 2020, HCPCS codes G2061, G2062, and G2063 have been deleted from the list.

• Telehealth Visits

All traditional Medicare beneficiaries, regardless of originating site or geographic location, will be covered for telehealth visits. However, a pre-existing relationship with a patient is not required to provide a telehealth visit. Instead, telehealth/e-visits can be provided using Skype, FaceTime, and other common communication technologies. Therefore, you can bill audio-only or audio-video telehealth visits the same way you would an in-person visit. These codes are meant for synchronous visual/ audio evaluation and management visits for:

99201-99205: New patient office/outpatient E/M visit

99210-99215: Established patient office/outpatient E/M visit

G0425-G0427: Initial inpatient telehealth consultations for emergency department (Medicare only)

G0406-G0408: Follow-up inpatient consultations for patients in hospitals or SNFs (Medicare only)

Modifier 95: Use on an interim basis for Medicare telehealth billing companies by most commercial payers

Point to Remember:

Place of Service code “02” is required by Medicare for telehealth services.

• Telephone E/M Services

Telephone or audio-only evaluation and management (E/M) services for established and new patients may neither be led to an E/M service or procedure within the next 24 hours nor derived from a related E/M service provided within the previous 7 days or the next available appointment. Medicare and some Medicaid programs cover these services on an interim basis for medical discussions for a duration of:

99441: 5-10 minutes

99442: 11-20 minutes

99443: 21-30 minutes

Enhance your Reimbursements!

Undoubtedly, the provisions of the Final Rule will significantly impact the prospects of telehealth and digital services in the context of the Medicare Program and beyond beginning in January 2023. However, the billing guidelines for digital and telehealth services are still being developed. In fact, the rules for billing digital and telehealth services vary from payer to payer (Medicaid, Medicare, private payers, etc.).

To know more, you can contact the 24/7 Medical Billing Services team to enhance your reimbursements ultimately.

Read more: Medicare Payment Rules For Telehealth Billing Services