As the Coronavirus has started to overwhelm our physicians and hospitals, we are sharing some of our resources to ensure you have important CMS information in this new phase of patient care. On March 17th Seema Verma, CMS Administrator, issued new guidance for billing Telehealth service. This benefit has greatly expanded with regards to technology, patient location, and HIPAA rules. Prior to this release, CMS issued a public health news alert (February 13th) announcing the new HCPCS codes to be used for testing. Here’s a summary of the latest information to share with your medical teams and billing staff.
Billing – Tests and Diagnosis Codes
Providers using the CDC 2019 Novel Coronavirus real time RT-PCR diagnostic test panel, bill HCPCS code U0001.
Facilities and labs using the 2019-nCoV Coronavirus, SAR-CoV-2/2019-nCoV using any technique, multiple types or subtypes (including all targets), bill HCPCS code U0002.
Note CMS will begin accepting claims for services on or after February 4, 2020 starting April 1, 2020.
ICD-10 – CDC Guidance
Exposure
Z03-818 - Suspected to COVID-19 – encounter for observation for suspected exposure to other biological agents ruled out
Z20.828 – Confirmed exposure to an individual having COVID-19, contact with and (suspected) exposure to other viral communicable diseases
Signs & Symptoms
Use these codes where signs/symptoms are present and where a definitive diagnosis has not been established
R05 Cough
R06.02 Shortness of breath
R50.9 Fever, unspecified
Other General Guidance
Pneumonia
J12.89, Other viral pneumonia with B97.29 other coronavirus as the cause of the diseases classified elsewhere
Acute Bronchitis
J20.8 Acute bronchitis due to confirmed COVID-19, J22 bronchitis not otherwise specified, J40 bronchitis, not specified as acute or chronic, and B97.29 other coronavirus as the cause of the diseases classified elsewhere
Lower Respiratory Infection
J22 if COVID-19 is being associated with a lower respiratory infection or acute respiratory infection NOS. J98.8 if COVID-19 being associated with a respiratory infection, NOS. Use these in combination with B97.29 other coronavirus as the cause of the diseases classified elsewhere
ARDS
J80 acute respiratory distress syndrome due to COVID-19 with B97.29 other coronavirus as the cause of the diseases classified elsewhere
Telehealth Guidance
Yesterday marked an important step for expanding the use of telehealth services. Not only are all the geographic boundaries lifted, patients can now be at home to receive a telehealth service. This was instituted to allow at-risk patients the option to not travel and also mitigate community spread.
Under the Emergency waiver (Section 1135(b) of the Social Security Act, providers can now use telephones have audio/video capabilities and/or apps such as Skype, Facetime, or Zoom to create that audio/video connection. As long as providers are acting in good faith through everyday communication, these modalities are acceptable. This applies for all types of care and not limited to COVID-19.
Acceptable providers include physicians, nurse practitioner physician assistants, and certified nurse midwives. Other practitioners, such as certified nurse anesthetists, LCSW’s, clinical psychologists, registered dieticians or nutrition professionals may also furnish services under their scope of practice and consistent with CMS rules – this did not change with the waiver.
You can find the list of approved telehealth services here: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes. Note that new (99201-99205) and established (99211-99215) are billable along with initial inpatient (99221-99223) and (99231-99233) as many of your main services. Documentation would be no different than if the patient was in the office. Note, you would need to use a time statement for new patient codes where an exam did not take place. Remember the time statement should have total time and percent counseling time (over 50%), along with what you discussed with the patient. Each CPT service has an average time. Always round counseling time down versus up. CMS MAC’s have different rules for place of service – we have seen both 02 (telehealth) and 11 (office). Validate with your MAC to ensure these are processed accurately.
Virtual Visits
Virtual visits are a scaled down visit as compared to telehealth. G2012 can be used for virtual check-in’s, by telephone, for an established patient. This code could be very useful for non-emergent visits where a prescription might need to be filled or troubleshoot symptoms. Time should be reported between 5-10 minutes with this service along with a summary of the discussion and plan. If the patient has been seen the past 7 days or requires a visit within 7 days (or next available visit) then this would not be reported.
Similarly, for a ‘store and forward’ visit (patient sending videos or pictures), use code G2010. Both types of virtual visits cannot be billed incident-to for purposes of CMS. You will also need to get a verbal blanket waiver for all virtual services that can be valid for one year.
Interprofessional Consultations
These codes are intended to be used to assess and manage services conducted through telephone, internet, or electronic health records. Interprofessional consultations are furnished when a patients treating physician or other qualified healthcare professional requests the opinion and/or treatment advice of another physician, with specific specialty expertise, to assist in the diagnosis and/or management of the patient’s problem, without the need for the patient’s face-to-face contact. These codes are very useful for healthsystems where specialists are at a shortage. Currently, pulmonologists are so focused in hospitals, this could be a means for clinicians to review cases and decide which referrals require a face-to-face visit as opposed to those they can advise and treat, through another provider, without a visit. Note the time increments required for discussion and review with the referring or primary care provider.
Patient can be new or established and limited to those providers that can independently bill for an E/M services. If patient was seen by the consultant in the past 14 days or is scheduled in the next 14 days or soonest appointment, these codes should not be reported. If more than 50% of the time was spent reviewing data vs. consulting with treating physician and a report was generated, use code 99451.
• 99446 - Interprofessional telephone/internet, EHR assessment and management service provided by a consultative physician, including verbal and written report back to the treating/requesting physician or QHP – 5-10 minutes of discussion and review
• 99447 - 11 – 20 minutes of discussion and review
• 99448 - 21 – 30 minutes of discussion and review
• 99449 - 31 minutes or more of discussion and review
• 99451 - 5 minutes or more, written report only
The referring (or treating) provider also has a code that can be billed for prepping the communication. This provider must spend a minimum of 16 minutes and this service cannot be billed more than once in a 14-day period. Referring providers can also use prolonged services if time exceeds 30 minutes beyond the typical time (patient not face-to-face – 99358).
• 99452 - Interprofessional telephone/internet, EHR assessment and management service provided by the treating/requesting physician or QHP
Digital E-Visits
E-visits are patient initiated digital communication visits and can be billed by a physicians or qualified healthcare practitioner. CPT code definitions will enforce the 7-day rule (not relating to a previous or leading to a follow-up evaluation and management visit). The codes require permanent documentation storage in an EMR or similar type record. These cannot be combined with other virtual check-in visits and do require a waiver to notify patient’s of their cost-sharing portion. CMS announced blanket waivers for virtual and e-visits are acceptable for a period of one year.
• 99421 – On-line digital E/M service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes (.25 RVU)
• 99422 - On-line digital E/M service, for an established patient, for up to 7 days, cumulative time during the 7 days; 11-20 minutes (.50 RVU)
• 99423 - On-line digital E/M service, for an established patient, for up to 7 days, cumulative time during the 7 days; 21+ minutes (.80 RVU)
Important Links
March 18th - CMS State Medicaid and CHIP Press Release:
https://www.medicaid.gov/state-resource-center/downloads/covid-19-faqs.pdf
March 17th – CMS Expansion of Telehealth benefits during COVID-19:
March 17th – CMS Telemedicine Fact Sheet:
https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet