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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