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Covid-19 Article Update

Wednesday, April 22, 2020   (0 Comments)
Posted by: Joy Newby, LPN, CPC, Newby Consulting Inc
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Dateline 4/22/2020


Additional information has been made available requiring an update to the article published on 4/9/2020. Changes are noted below.


For Original Medicare, the physician must use an interactive audio and video telecommunications system that permits real-time communication between the distant site and the patient at home. §410.78(a)(3) states that telephones, facsimile machines, and electronic mail systems do not meet the definition of an interactive telecommunications systems for purposes of Medicare telehealth services.

Effective March 6, 2020, on an interim basis during the public health emergency (PHE) for the COVID–19 pandemic, CMS specified that the office/outpatient E/M level selection for these services when furnished via telehealth can be based on MDM or time, with time defined as all of the time associated with the E/M on the day of the encounter; and to removes any requirements regarding documentation of history and/or physical exam in the medical record. When reporting by time, physicians should use the 2021 times associated with the office/outpatient E/M codes.

  • 99201 – 1-14 minutes
  •  99202 – 15-29 minutes
  • 99203 – 30-44 minutes
  • 99204 – 45-59 minutes
  • 99205 – 60-74 minutes
  • 99212 – 10-19 minutes
  • 99213 – 20-29 minutes
  • 99214 – 30-39 minutes
  • 99215 – 40-54 minutes

When reporting by time, physicians should use the 2020 times associated with the office/outpatient E/M codes.

  • 99201  10 minutes
  • 99202  20 minutes
  • 99203  30 minutes
  • 99204  40 minutes
  • 99205  60 minutes
  • 99212  10 minutes
  • 99213  15 minutes
  • 99214  25 minutes
  • 99215  40 minutes

For the duration of the COVID-19 Public Health Emergency, Medicare will make payment for Medicare telehealth services furnished to beneficiaries in any healthcare facility and in their home.

Medicare coinsurance and deductible would generally apply to these services. However, the HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.

Please remember that you must explain to the patient they will be charged for the non-face-to-face encounter and obtain their verbal permission to perform the service. This information must be documented in the medical record.

Although the rule was posted on 3/30/2020, it was not published in the Federal Register until April 6, 2020.

To bill for telehealth services, the physician should

  • Report the appropriate office/other outpatient E/M code (99201-99215) that describes the service
  • Append modifier -95 to the CPT code
  • Per the Interim Final Rule, published April 6, 2020, physicians and practitioners are not to report POS 02 for telehealth services. During the PHE, physicians and practitioners who bill for Medicare telehealth services are instructed to report the POS code that would have been reported had the service been furnished in person. This will allows Medicare to make appropriate payment for services furnished via Medicare telehealth which, if not for the PHE for the COVID–19 pandemic, would have been furnished in person, at the same rate they would have been paid if the services were furnished in person.

UnitedHealthcare is waiving the Centers for Medicare and Medicaid’s (CMS) originating site restriction and audio-video requirement for Medicare Advantage, Medicaid, and Individual and Group Market health plan members from March 18, 2020 until June 18, 2020. Eligible care providers can bill for telehealth services performed using interactive audio-video or audio-only, except in the cases where we have explicitly denoted the need for interactive audio/video, such as with PT/OT/ST, while a patient is at home.