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Don’t get your wires crossed during telephone E/M encounters

The big pay boost for telephone E/M codes performed by physicians and qualified health care professionals (99441-99443) is good news for practices that have performed audio-only telephone encounters during the COVID-19 emergency.
In addition, the update should remind practices to make sure they know when they can report an office E/M telehealth visit and determine if their state’s Medicaid program will reimburse the practice for audio-only encounters.
In the interim final rule released April 30, CMS announced that it would raise payments for the time-based telephone E/M codes because many Medicare patients could not or would not use the technology required for an encounter that can be reported with an office E/M code during the emergency.
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Before CMS issued the upwardly revised payment rates, the telephone E/M codes paid far less. You would have gained $14.44 for each 99441 claim, $28.15 for your 99442 claims and $41.14 for 99443 claims. For the five- to 10-minute telephone E/M code 99441, that marks a 220% pay increase.
Medicare will continue to cover telephone E/M services performed by qualified non-physician clinicians who cannot bill E/M services (98966-98968), but the pay for those codes won't increase.
The update is retroactive to March 1. Medicare will likely correct payments for services performed between March 1 and the update, but stay tuned for additional details.
Practices may continue to report telehealth with office E/M codes (99201-99215) to Medicare under the relaxed rules that are in effect during the COVID-19 emergency. For example, encounters conducted via a smart phone or tablet qualify so long as the clinician and the patient maintain a real-time, two-way audio/visual encounter.

In addition, practices should check their state’s emergency declarations to see if they may report an audio-only encounters. For example, Maryland announced that it would allow audio-only telehealth services in a March 20 order that was updated April 1.
Make sure this information reaches relevant people in your practice’s reimbursement and keep an eye peeled for new changes, especially as your state winds down its COVID-19 curve flattening measures.
Finally, if you like any of the changes CMS put in place during the emergency, submit a comment by July 7. The agency is seeking feedback on what – if any – of the changes should be permanent.
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