Office telehealth visits can be coded based on time or MDM, telephone E/M covered

by: Julia Kyles, CPC Mar 31, 2020

You’ll be able to test drive the 2021 guidelines for E/M office visits and report telephone E/M services during the COVID-19 pandemic, according to an interim final rule released at the end of the day.

As Part B News has reported on its blog, CMS and other divisions of the Department of Health and Human Services have launched a massive drive to make telehealth accessible to practices and patients.

Here’s a quick summary of E/M-related changes that will take effect March 31 and will run for the duration of the current COVID-19 emergency.

Code office E/M via telehealth based on time or MDM

Get a preview of how you’ll code office visits next year when you report telehealth office visits. The interim rule will allow practices to use the current medical decision-making or typical times to select a code for a telehealth visit during the emergency. However, time is “defined as all of the time associated with the E/M on the day of the encounter,” which echoes next year’s standards.

“This policy only applies to office/outpatient visits furnished via Medicare telehealth, and only during the [public health emergency] for the COVID-19 pandemic,” the rule states.

Report telephone E/M visits

When a phone conversation with a patient goes beyond a virtual check-in as described by HCPCS code G2012, you’ll be able to turn to the time-based phone codes in your CPT manual, the interim rule states. Physicians and qualified health care professionals who can report E/M services may use the following codes:

99441 (Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion).
99442 ( …; 11-20 minutes of medical discussion).
99443 ( …; 21-30 minutes of medical discussion).

When the service is performed by a qualified health care professional who can’t bill for E/M services, such as a licensed clinical social worker or a physical therapist, turn to the medicine codes, which will be listed as sometimes therapy codes to facilitate billing by physical therapists:

98966 (Telephone assessment and management service provided by a qualified nonphysician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion).
98967 ( …; 11-20 minutes of medical discussion).
98968 ( …; 21-30 minutes of medical discussion).

You can ignore the restriction to established patients in the descriptors. CMS is “exercising enforcement discretion on an interim basis to relax enforcement of this aspect of the code descriptors,” the rule states.

This is a breaking news story. Please check back for additional updates.

Blog Tags: Breaking news, COVID-19, telehealth

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Steven Miller

Apr 14, 2020 12:49 PM

We have followed this guidance and used the POS at 11 and no modifier and still are getting denials for 99441-99443. What other guidance is suggested?

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