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Virtual Services During the Time of COVID-19

Public and private insurers have taken steps to increase telehealth services during the public health emergency due to COVID-19. CMS is expanding its Virtual Services benefits on a temporary and emergency basis. The expanded benefit is retroactive to March 1, 2020 and allows patients to receive care at their place of residence rather than in a physician office or a hospital. The most recent expansion included payment for telephone calls with patients.

Part of the expanded benefits include allowing telehealth services to be reported by a variety of non-public facing technologies. The requirement for synchronous audio/visual requirements remains. Services can be reported for both new and established patients and should be reported using the same code (i.e. 99201-99215) that would have been reported if the patient was seen for an in-person visit. Reimbursement will be the same as if the patient was seen in the office or other appropriate setting. Levels of service for office visit codes can be based on either time or medical decision-making. It is not necessary to meet the documentation requirements related to the key components (history, exam, medical decision-making) when selecting a level of service.

Based on input from the medical community, CMS previously announced that Medicare would pay for certain services conducted by audio-only telephone between beneficiaries and their doctors and other clinicians. Now, CMS is also increasing payments for these telephone visits to match payments for similar office and outpatient visits. This would increase payments for these services from a range of about $14-$41 to about $46-$110. The payments are retroactive to March 1, 2020. The codes for telephone services (99441-99443) are time-based services and have restrictions on reporting when they are provided in conjunction with other patient encounters. It is important to read the CPT instructions for reporting telephone services to understand the requirements and limitations associated with these codes.

AAPM offered a webinar "Coding Services in the Wake of COVID-19" on April 15 that addresses the appropriate coding and reporting of telehealth services and other virtual services covered by Medicare. The webinar can be accessed here.

AAPM also convened a panel of pain medicine experts to present a webinar, "Pain Management Best Practices During the COVID-19 Pandemic and Public Health Crises: A Discussion of the New Guidelines." This webinar is also available and can be viewed here.

Guidelines are changing as payers attempt to revise policies and adjust their systems to meet policy changes. You should visit your Medicare, Medicaid and private payers' websites and/or read all payer communications to determine coverage and specific instructions. 

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