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Go to your room: Counseling patients to isolate after COVID-19 tests is a billable service [Update]

CMS and the CDC agree: If your practice is testing for COVID-19, a physician or qualified health care professional should counsel the tested patients about what to do and what to expect while they wait for results, and they can be paid for the counseling.
Isolation during this period can significantly reduce transmission, and the practice will be able to report an E/M service when eligible practitioners counsel patients, according to the joint CMS/Centers for Disease Control and prevention announcement released today.
The conversation should take place when the test is performed and include:
  1. The need for immediate isolation while the patient waits for their test results.
  2. Services the patient might need to help them isolate at home.
  3. A review of the symptoms of COVID-19.
  4. Advice to tell inform members of the patient’s household that they should consider getting tested and self-isolate.
  5. What to expect if they test positive, including encouragement to work with contract tracers.
Documentation – and remembering what to discuss – will be easy with the counseling checklist that CMS has created for the encounter. The checklist also contains a collection of helpful links for clinicians and patients, such as “3 steps to take while waiting for your COVID-10 results.”
The E/M service can be reported by clinicians who are eligible to report counseling services so don’t leave this task to clinical staff. In addition, it may be reported “no matter where a test is administered, including doctor’s offices, urgent care clinics, hospitals and community drive-thru or pharmacy testing sites,” the announcement states.
Take note of the additional coverage and coding tips CMS issued after this post was published:
  • You can report the service for Medicare and Medicaid patients.
  • You may bill for counseling when it is performed as part of a telehealth service.
  • Practitioners should document their time for code selection. But how you count the minutes may depend on the nature of the encounter:
  1. In-person encounters: Practitioners will follow the coding rule that allows an encounter to be coded based on time when counseling/coordination of care makes up more than 50% of the visit. The reportable time is the total face-to-face time in office and other outpatient settings and the total unit/floor time in hospital inpatient settings.
  2. Telehealth encounters: Practices that report counseling services via telehealth “should select the appropriate E/M code level based on the total time that the practitioner personally spends furnishing the service on the day of the visit (including face-to-face, i.e., during the telehealth visit, and non-face-to-face time),” the guidance states. But stay tuned for more information. The interim final rule released March 31 restricted the ability to count total time spent on the day to office E/M visits reported via telehealth (99201-99215). The new guidance appears to allow day-of time coding for any telehealth E/M encounter.
Blog Tags: COVID-19
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