As doctors offices begin to reopen, the use of telehealth is plateauing, and in some cases declining, after a surge during the COVID-19 public health emergency (PHE). According to recent data from The Commonwealth Fund, telehealth accounted for about 14% of all visits the week of April 19, but dropped to 13% the next week and 12% the week after that, where it held steady for the first two weeks of May.
But that doesn’t mean telehealth will return to limited pre-pandemic use any time soon. The flexibilities enacted by the Centers for Medicare and Medicaid Services (CMS) remain in place through the end of the PHE, and this week the Trump administration announced expanded access to telehealth for Medicare Advantage plans.
Back in March, we covered the temporary changes in telehealth by Indiana Medicaid and Medicare, with updates later in April and May. Today we want to narrow in on one aspect of telehealth that Medicare has greatly expanded during the PHE: telephone, or audio-only, telehealth services.
First, let’s review another audio-only service that was available prior to the COVID-19 PHE.
Beginning in 2019, Medicare began covering brief virtual check-ins, including telephone calls, which were for established patients only. According to the definition for G2012, this 5-10 minute virtual check-in should not originate from a related E/M service provided within the previous 7 days nor lead to an E/M service or procedure within the next 24 hours or soonest available appointment. Rather the check-in is intended to avoid a more extensive in-person or telehealth visit.
Medicare continues to cover virtual check-ins during the COVID-19 PHE, and physicians can bill the service for new patients in addition to established patients.
Telephone E&M Visits
During the COVID-19 PHE, Medicare will also cover telephone E&M visits for new and established patients using CPT codes 99441-99443. These codes are time-based, with 99441 selected for a five- to 10-minute medical discussion, 99442 for an 11- to 20-minute medical discussion, and 99443 for a 21- to 30-minute medical discussion.
Like virtual check-ins, the telephone E&M visits should not originate from a related E/M service provided within the previous 7 days nor lead to an E/M service or procedure within the next 24 hours or soonest available appointment. These telephone E&M visits are distinct visits rather than preservice or follow-up visits.
“When clinicians are furnishing an evaluation and management (E/M) service that would otherwise be reported as an in-person or telehealth visit, using audio-only technology, practitioners may bill using these telephone E/M codes, provided that it is appropriate to furnish the service using audio-only technology,” CMS writes in the online document “Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19.”
Unlike other telehealth services, telephone E&M codes do not require telehealth modifiers, since the codes are specific to telephone use.
In addition to allowing the use of these codes for new patients, Medicare flexibilities during the COVID-19 PHE also include increased payment for these telephone E&M services. From March 1, 2020, through the end of the PHE, CPT codes 99441-99443 will be reimbursed the same as for in-person or telehealth services using E&M codes 99212-99214. Because this payment increase came several weeks after the codes were first added to the approved telehealth list, Medicare Administrative Contractors (MACs) will automatically reprocess claims for those services that they previously denied and/or paid at the lower rate.
Cost-sharing does apply for Medicare recipients, unless providers choose to waive cost-sharing under earlier Medicare telehealth flexibilities. The American College of Physicians recommends that physicians “document verbal consent (because of cost-sharing requirements) and why in-person or audio-video encounter [is] not possible.”
Other Audio-Only Services
According to CMS, many other behavioral health, education, and therapy services may now be furnished via telehealth using audio-only communications during the COVID-19 PHE. The full list of telehealth services available from the Medicare website highlights which services are eligible to be furnished via audio-only technology.
Other government payers and some commercial payers also are covering audio-only telehealth services during the pandemic. Check with the payers in your area to confirm coverage and billing guidelines.
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