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Resource Telehealth

Telemedicine-“a two-way, real- time interactive communication between a patient and a physician or practitioner at a distant site through telecommunications equipment that includes, at a minimum, audio and visual equipment.”

Telemedicine services may make up 2 distinct services, depending on where the patient is located during the telemedicine encounter. Table 1 outlines the different coding and billing requirements whether you are the “performing physician/provider” or the “hosting facility.” In addition, since alternate terms may be used, we have included those, as well:

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What happens next with telehealth services after the PHE?
Reimbursement will require coders to know which waivers to Medicare coverage & payment policies end on May 11, 2023.
The Consolidated Appropriations Act, of 2023, extended many telehealth flexibilities through December 31, 2024.

  • People with Medicare can access telehealth services in any geographic area in the United States, rather than only those in rural areas.
  • People with Medicare can stay in their homes for telehealth visits that Medicare pays for rather than traveling to a healthcare facility.
  • Certain telehealth visits can be delivered audio-only (such as a telephone) if someone is unable to use both audio and video, such as a smartphone or computer.”

Guidance for Telehealth​

  • Office and other outpatient visits (99202-99215) will continue to be covered for Medicare patients through the end of 2024. However, an audio AND video connection with the patient is required and the visit must be medically necessary (with documentation supporting the claim).
  • Incident-to services will no longer be allowed via virtual supervision beginning Jan. 1, 2024.
  • Initial hospital and observation services (99221-99233) will remain on CMS’ Telehealth Code List until no longer needed.
  • All telehealth platforms must again be HIPAA compliant per Office of Civil Rights guidelines starting Aug. 9, 2023, which is 90 days after the end of the PHE. The use of smartphone video options, such as FaceTime and Skype, will be non-compliant after Aug. 9, 2023.
  • Medicare will continue to allow audio-only telephone services to be reported with codes 99441-99443 for physicians and other qualified healthcare professionals, but the CPT® rules for using these services will apply. This means that you can use these codes for established patients only. Payment parity to evaluation and management (E/M) codes 99212-99214 (when modifier 95 is used) will end on Dec. 31, 2024.
  • “Certain” behavioral and mental health services will now be permanently offered under telehealth for Medicare patients. Please review CMS’ List of Telehealth Services to know what falls under this policy. E/M services are not part of this policy.
  • Place of service (POS) codes will continue to be based on where the patient would have been had they been seen in person. However, POS 02 Patients not in their home when telehealth services are rendered, or POS 10 Patients in their home when telehealth services are rendered, may be reported. Reporting these specific POS codes will result in facility reimbursement.
  • You should continue to use Modifier 95 for audio and video services for Medicare telehealth services through 2024.
  • Modifier 93 was listed on the CMS news alert as a valid modifier to use on audio-only telehealth services, but CMS has not said this is mandatory during the extension period of flexibilities. Commercial plans will have individual contract rules on this modifier, so please check with your payers on their direction.

 
Billing For Telehealth Encounters
An introductory guide on fee for service

Some great tips in here!

Originating Site
Distant Site
Eligible Providers
Codes
Modifiers
Place of Service Codes
The Rest of the POS Codes
Revenue Codes
Services 'Evaluation and Management CPT Codes
Other E/M Services
Communication Technology Based Services (CTBS) – Non-Telehealth Technology Services
Remote Evaluation and Virtual Check-in
Care Management (CM) Codes
Remote Physiological or Patient Monitoring (RPM)18 Remote Therapeutic Monitoring (RTM)
eConsult or Interprofessional Consultation Codes & eVisit ...

The Center for Connected Health Policy (CCHP) is providing this informational billing guide to assist those who have questions regarding telehealth billing in general and specifically, post-PHE. The guide is primarily about Medicare fee-for-service billing as policies vary from state-to-state for Medicaid and commercial payers. It is not meant to be a guarantee of reimbursement for services rendered via telehealth, but to act as a guide to clarify certain policies related to: • telehealth billing and reimbursement • requirements applicable during 2023 (in the post-PHE environment)

• permanent telehealth billing requirements past the temporary grace period post-PHE The guide will outline the policies in place for 2023, as well as permanent Medicare policy as we currently know it. Keep in mind, policy can change rapidly and frequently. ) PE

Permanent Medicare Policy

Outpatient Prospective Payment System (OPPS)

Three codes were added to the CMS Telehealth List on May 9, 2023 and are discussed below.

Since the PHE allowed Partial Hospitalization and Intensive Outpatient Program services to take place in a patient’s home via telehealth, the following occurred:
In the CY 2023 Outpatient Prospective Payment System final rule, CMS established a policy that allows clinical staff of hospitals to provide certain mental health services via a telecommunications system to patients in their homes after the PHE. They established 3 new codes and code descriptors (C7900-C7902) for these remote mental health services furnished by hospital outpatient department (HOPD) staff. Because HCPCS codes C7900 – C7902 describe remote mental health services furnished by hospital staff to a patient in their home, and the statute prohibits Partial Hospitalization Program (PHP) services from being furnished in an individual’s home, these are not considered PHP services, and CMHCs can’t furnish these remote services. However, patients receiving PHP services from a CMHC or hospital-based PHP could receive the remote mental health services from clinical staff of a HOPD. The policy discussion starts at 87 FR 72014.
The code definitions are as follows:

• C7900 - Service for diagnosis, evaluation, or treatment of a mental health or substance use disorder, initial 15-29 minutes, provided remotely by hospital staff who are licensed to provide mental health services under applicable state law(s), when the patient is in their home, and there is no associated professional service
• C7901 - Service for diagnosis, evaluation, or treatment of a mental health or substance use disorder, initial 30-60 minutes, provided remotely by hospital staff who are licensed to provided mental health services under applicable state law(s), when the patient is in their home, and there is no associated professional service
• C7902 - Service for diagnosis, evaluation, or treatment of a mental health or substance use disorder, each additional 15 minutes, provided remotely by hospital staff who are licensed to provide mental health services under applicable state law(s), when the patient is in their home, and there is no associated professional service (list separately in addition to code for primary service)

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