Practices should keep a careful eye on their virtual check-in claims — and heed the codes' billing timelines — after an OIG audit found millions of dollars in improper payments for the technology-based services.
The OIG audit, released April 28, arrives roughly a year after practices made the switch from a HCPCS code (
G2012) to a CPT code (
98016) to report virtual check-in services. Code 98016
took effect Jan. 1, 2025, and is reported far more often than the "store and forward" virtual check-in code
G2010.
For its audit, the OIG analyzed diagnosis codes on claims for E/M office visits and virtual check-ins to assess whether the services overlapped. Under Medicare's billing rules, the virtual check-in should not be related to the reason for an E/M office visit that occurred within the previous seven days, nor should it be related to an E/M visit that occurs within the next 24 hours. In the event the visits are related, the virtual check-in is not separately reportable, according to CMS.
In its report, the OIG offers an example:
"A provider saw an enrollee on Thursday, November 5, 2020, and billed for an E/M service with the diagnosis code E78.5 — a billable code used to diagnose hyperlipidemia, a condition characterized by high levels of lipids in the blood. CMS paid the provider $42.52 for the E/M service. The provider also billed and provided two virtual check-in services with the same diagnosis code (E78.5) that Friday and Monday (November 6 and 9, 2020) for $10.43 each. If these virtual check-in services were related to the same medical condition addressed on November 5, the provider should not have billed separately for the virtual check-in services (totaling $20.86) since they were within 7 days of the E/M service."
The OIG also looked at virtual check-in claims appended with payment modifier 25, 95 and GT, which in some cases may "contradict the billing requirements" for the service, the OIG says.
All told, the OIG estimates that CMS made $1.96 million in improper payments for the G2012 and G2010 services. The OIG attributed roughly $1.6 million of the improper payments to inappropriate claims submissions based on timing or medical necessity and about $337,000 to modifier-related miscues.
"CMS made these potentially improper payments because CMS and MACs did not have system edits in place to identify communication technology-based services that may have been related to the same medical conditions addressed during other services," the OIG states in the
audit report. "Also, providers may not have been aware of CMS requirements for billing these newly created services."
Practices should tighten up their reporting of virtual check-ins. Following the audit, CMS has agreed to strengthen "system edits" that would deny inappropriate claims. The agency also said it would continue to educate providers about proper billing requirements.
As a reminder, check out the full descriptors of the virtual check-in codes:
- G2010 (Remote evaluation of recorded video and/or images submitted by an established patient [e.g., store and forward], including interpretation with follow-up with the patient within 24 business hours, 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)
- G2012 (deleted, as of Dec. 31, 2024)
- 98016 (Brief communication technology-based service [eg, virtual check-in] by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related evaluation and management service provided within the previous 7 days nor leading to an evaluation and management service or procedure within the next 24 hours or soonest available appointment, 5-10 minutes of medical discussion)
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