June 18, 2021 | By Bryan Meek, Esq., Brennan, Manna, and Diamond
The pandemic has undisputedly changed the way in which Americans live their daily lives, including how they receive medical care. Patients have increasingly been receiving care via telemedicine, virtual check-ins, or e-visits in order to avoid physically going to their appointments and risking exposure. However, it is important to keep in mind that billing codes for virtual visits are not documented the same as for physical visits, and not all telehealth visits are equal either, and it is important that healthcare providers continue to be reminded of these requirements and audit for compliance, especially after the initial COVID-19 leniency periods come to an end. Federal health payors such as Medicare and Medicaid have released guidance on what is reimbursable under their programs, as well as specific CPT and HCPCS codes that apply to these different visits.
Before the pandemic, the Centers for Medicare and Medicaid Services (CMS) only covered a limited number of services provided via telehealth. Initially, telehealth visits were only covered by Medicare for people who lived in rural areas. However, to limit people physically entering clinics or hospitals in order to avoid exposure to COVID-19, coverage was expanded on March 6, 2020 through the 1135 Coronavirus Preparedness and Response Supplemental Appropriations Act on an emergency basis.
Telemedicine involves a provider and patient communicating in real-time, in lieu of going to a doctor’s office or hospital. In order to be reimbursed for telemedicine visits, the following requirements must be met:
The provider uses audio and video that allows for real-time communication between the provider and the patient. The provider is someone who is able to receive payment for the services (physicians, nurse practitioners, physician assistants, etc.);
The provider and patient must have an established professional relationship before claims can be submitted under Medicare, however, during the pandemic, new patients are allowed to utilize these services because audits are temporarily not being conducted.
The most common billing codes used for telemedicine visits that CMS provides are 99201 through 99215 for office or outpatient visits, G0425, G0424, and G0427 for consultations, emergency department, or initial inpatient visits, or G0406, G0407, and G0408 for follow-up inpatient consultations. However, CMS also provides a link to an exhaustive list at: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes
In contrast, virtual check-ins are just a brief conversation between the provider and patient (5-10 minutes), which is usually the initial step taken before deciding whether a longer visit is necessary. Additionally, only check-ins of patients who have an established relationship with the provider are reimbursable, and the patient must be the one initiating the communication. HCPCS codes G2012 (for phone calls), and G2010 (for video or images) can be used to bill for these services – but providers may also communicate with patients via email, patient portal, or text.
Lastly, e-visits involve communications between the provider and patient that occur asynchronously through a patient portal, and may be paid for by Medicare Part B. As with virtual check-ins, these communications must be consented to by the patient, and the patient must already have an established relationship with the provider. The CPT codes utilized by physicians and nurse practitioners are 99421, 99422, and 99423, while other providers such as physical therapists and psychologists, who do not independently bill, can use HCPCS codes G2061, G2062, and G2063.
Providers should be aware of the various forms of telehealth visits to ensure that the correct codes are being billed for the service actually being provided. Additionally, it will be important to keep an eye on the 1135 Coronavirus Preparedness and Response Supplemental Appropriations Act, because when this emergency is no longer in effect, some of the telemedicine services now covered under Medicare may no longer be covered.
If you need additional assistance regarding insurance coverage, telehealth, or other claim submission, please do not hesitate to contact Bryan E. Meek, Esq. (330-253-5586 or firstname.lastname@example.org), who is an attorney in Brennan, Manna & Diamond’s Provider Relations, Audits, and Appeals Unit, a division of BMD’s Healthcare Department. You can also Subscribe to his YouTube channel: Employment Law After Hours here: https://www.youtube.com/channel/UCv0-oZk-tFq-DRIPvRP3icw
 Centers for Medicare & Medicaid Services, Medicare Telemedicine Health Care Provider Fact Sheet (Mar. 17, 2020), https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet (accessed May 25, 2021).