Q: Do telehealth visits require audio and video capabilities?
A: Yes, but with the relaxation of HIPAA-compliant equipment during the federal emergency, smart phones with audio/video capabilities are eligible using programs such as FaceTime and Skype.
Q: What types of telehealth visits will Medicare reimburse under waiver 1135?
A: Telehealth visits – synchronous audio/video visits using CPT codes 99201-99215. Virtual check-ins – 5 to 10-minute visits performed via telephone or audio/video and billed with HCPCS codes G2010 or G2012. E-visits – These can be performed via a doctor portal using codes 99421-99423 for physicians or G2061-G2063 for other qualified healthcare professionals
Q: How does a qualified provider bill for telehealth services?
A: Medicare telehealth services are generally billed as if the service had been furnished in-person. For Medicare telehealth services, the claim should reflect the “regular” Place of Service for Telehealth with modifier 95 applied to indicate “telehealth service”.
Q: Will CMS require specific modifiers to be applied to the existing codes?
A: CMS is not requiring additional or different modifiers associated with telehealth services furnished under these waivers. However, consistent with current rules, there are three scenarios where modifiers are required on Medicare telehealth claims. In cases when a telehealth service is furnished via asynchronous (store and forward) technology as part of a federal telemedicine demonstration project in Alaska and Hawaii, the GQ modifier is required. When a telehealth service is billed under CAH Method II, the GT modifier is required. Finally, when telehealth service is furnished for purposes of diagnosis and treatment of an acute stroke, the G0 modifier is required.
Q: Does Medicaid and CHIP fall under the waiver 1135?
A: States and Territories can submit a waiver 1135 Request form to allow many of the flexibilities available under waiver 1135. The following states have already been granted flexibilities under waiver 1135: (as of 3/31/20)
- New Hampshire
- New Jersey
- New Mexico
- New York
- North Carolina
- Rhode Island
- West Virginia
Q: Have physician supervision levels been changed during this crisis?
A: Medicare Direct supervision is no longer required for non-surgical extended duration therapeutic services in hospital outpatient departments or critical access hospitals. Physicians can now provide general supervision. For services still requiring direct physician supervision by a physician or other practitioner, the supervision can now be provided virtually using real-time audio/video technology.
Q: Is care in a hospital required to be performed under a physician?
A: CMS is waiving the requirement that Medicare patients in the hospital be under the care of a physician. This allow physician extenders, such as physician’s assistants and nurse practitioners, to be used to the fullest extent possible. This waiver should be implemented in accordance with a state’s emergency preparedness or pandemic plan.
Q: Can providers work “out of state” to provide relief services?
A: Medicare and Medicaid are temporarily waiving the requirement that a provider be licensed in the state where they are providing services under the following conditions: 1) The provider must be enrolled in the Medicare program. 2) The provider must have a valid license in the state where they normally provide Medicare services. 3) The provider must be furnishing services, either in person or via telehealth, in a State in which the emergency is occurring in order to contribute to the relief efforts. 4) The provider is not excluded from practice in the State or any other state that is part of the 1135 emergency area.
Q: Must all diagnostic tests be performed in a hospital or imaging center?
A: No, group practices can perform medically necessary MRIs or CT scans from locations like mobile vans in parking lots that are rented by the group on a part-time basis.
Lori Shore, RCC,CPC, RCCIR, FRBMA
Vice President of Coding Education & Compliance