As part of an ongoing effort of CMS to streamline patient care and adopt more coverage for Telehealth services, providers will see several new coding options for CY2019. As per the Physician Fee Schedule final Rule published November 1st, CMS approved two new HCPCS codes to address established problems when utilizing telephone or internet exchange.
The first code G2012, should be used for established patients (see the CPT definition) where the patient and provider have an ongoing relationship. This code can be used if the patient’s problem has not originated from an E/M in the previous 7 days or, following the communication, will not lead to an E/M in the next 24 hours or soonest available appointment. This service is approved under the Physician Fee Schedule and not under the Telehealth benefits as this code does not require an originating site. CMS outlined in the final rule that only two-way real time audio in addition to two-way audio video are the only acceptable means of communication for this code. Clinical staff was not included in the definition as this service should be rendered by a physician or qualified health care provider and not provided ‘incident to’. Different than other coding services, the provider must document verbal consent by the patient and document this in the chart. This code requires cost sharing by the patient so documenting verbal consent will be key to ensuring this communication took place. Frequency limitations have not been set by CMS for 2019, yet CMS will be monitoring this code to ensure providers are using it appropriately.
• G2012 - Brief Communication Technology-based service e.g. virtual check-in by a physician or other qualified health care provider who can report evaluation and management services, provided to an established patient not originating from a related E/M service provided within the previous 7 days nor leading to an E/M or procedure within the next 24 hours or soonest available appointment – 5-10 minutes of medical discussion. RVU - Non-Facility =.41 Facility =.37
The second HCPCS G2010, was strongly vetted through public comment to set limitations on specialty and application to the new and established patient. CMS felt the code would be useful in a number of clinical setting thus keeping the definition open to all physicians. Similar to the virtual check-in code, this service is only applicable to established patients. Images can include pictures or video but not forms or data as per CMS. The follow-up statement within the code definition can take place via phone call, audio/video communication, secure text or email, or patient portal communication. As reported with G2012, frequency limitations have not been set however, CMS will be closely monitored. Services billed under this code must be medically necessary. CMS requires that verbal or written consent be documented in the chart.
• G2010 - Remote Evaluation of Recorded Video and/or images by the patient, (e.g., store and forward) including interpretation with follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment. RVU - Non-Facility =.35 Facility =.26
Complimentary Webinar!
If you would like more information on other E/M coding changes from the November Final Rule, send us a request at jana.gill@gillcompliance.com as we are offering a 30-minute complimentary webinar through December 31st.