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March 19, 2020

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Message from the AAPM President about COVID-19

​AAPM has been monitoring CDC guidance related to COVID-19. Today AAPM President Ajay D. Wasan, MD MSc issued the following message to members.

Dear Colleagues:

By now I am sure that you have received many lengthy COVID emails and so I will get to the point. AAPM has been monitoring CDC guidance related to COVID-19, and we offer the following thoughts to our members:

The CDC suggests delaying and not having patients come into the office for elective medical care. Certainly, it is a difficult issue to determine to what extent pain care is ‘elective’ vs. medically necessary, and the consideration for limiting outpatient pain care also depends on the extent of COVID-19 and the risk of acquiring it in your area.

At the very least it seems prudent to reschedule elective procedures/injections, initial evaluations, and follow-up visits in those patients at a high risk of complications from COVID-19. These subgroups include those 65 years old or older, those with important medical comorbidities (such as cardiac disease, pulmonary disease, or diabetes), the immunocompromised, and patients coming from nursing homes or long-term care facilities.

The CDC and the Trump administration have encouraged telemedicine visits in place of in-person follow up visits for elective medical care. The DEA has confirmed that it is reasonable in this crisis to renew controlled substance prescriptions after a telemedicine evaluation or telephone discussion with the patient when appropriate and if consistent with state law (such as by electronic prescribing to avoid a high risk patient coming in for a routine opioid follow up visit).

CMS has also relaxed the requirements for using telemedicine codes for billing and they have pledged to pay for these codes equivalent to in person visits. There are weblinks below that explain further how to use these codes effectively in your practice.

We are all struggling to adjust—both professionally and personally. In the coming weeks, our American Academy of Pain Medicine (AAPM) will work to keep us abreast of developments that are specific to our practice areas. Initially, we are providing updated billing and coding guidance that are consistent with the latest messaging coming from CMS regarding the expanded use of telemedicine codes. These insights were prepared under the guidance of the AAPM’s Coding and Reimbursement Committee, which represents our specialty at the CPT and RUC, and regularly provides information to AAPM members in the bi-monthly AAPM e-Newsletter.

Our AAPM will continue to monitor developments that are particular to pain medicine. Thank you for your continuing efforts on behalf of our patients.

Ajay D. Wasan, MD MSc
President AAPM

Providing and Reporting Medicare Telehealth Services During the COVID-19 Outbreak

The Centers for Medicare & Medicaid Services (CMS) has temporarily lifted restrictions on the use of telehealth services to allow beneficiaries to receive care without going to their physician’s office. CMS announced penalties will not be imposed on physicians using telehealth in the event of noncompliance with regulatory requirements under the Health Insurance Portability and Accountability Act. Other telehealth requirements such as patient location and the use of secure communication equipment are also lifted. These relaxed guidelines also apply to patients receiving care for conditions not related to COVID-19.

CMS indicated physicians who want to use audio or video communication technology to provide telehealth to patients during the COVID-19 nationwide public health emergency can use any non-public facing service that is available to communicate with patients. CMS specifically stated that physicians may use popular applications that allow for video chats, including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype to provide telehealth. Physicians should not use Facebook Live, Twitch, TikTok or other public facing communication services.

The CPT codes used to report telehealth services are the same as if the service was provided in your office. In most instances, this would be an Evaluation and Management Service (CPT 99201-99215). Likewise, the ICD-10 codes reported should be the primary reason for the patient encounter along with any other relevant diagnosis(es). The place of service code (POS) for telehealth (02) should be reported.

Medicare also covers online digital E/M Services (CPT codes 99421, 99422 and 99423) and corresponding codes G2061, G2062, G2063 when the service is provided by qualified non-physician health care professionals.CPT codes for telephone services (99441,99442,99443) are not covered by Medicare but may be covered by some commercial or managed care payers. The CPT guidelines for reporting on-line and telephone services should be reviewed prior to reporting.

It is not known if commercial or managed care payers will follow the CMS guidance on telehealth services. Therefore, you should check with other payers to determine their guidelines before reporting any form of telehealth or non-face-to face service.

Additional information on reporting telehealth services during the COVID-19 outbreak can be found at the following links:

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