Medicare Telehealth And Monitoring (RPM) Services

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Medicare Telehealth andRemote Patient Monitoring (RPM) ServicesCoding & Billing SummaryCOVID-19 ResponseUpdated 10/14/2020This information was prepared as a service to the public, and is not intended to grant rights or impose obligations. This information maycontain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be a generalsummary. It is not intended to take the place of either the written law or regulations. We encourage readers to review the specificstatutes, regulations, and other interpretive materials for a full and accurate statement of their contents.This material was prepared by the IPRO QIN-QIO, a collaboration of Healthcentric Advisors, Qlarant and IPRO, serving as theMedicare Quality Innovation Network-Quality Improvement Organization for the New England states, NY, NJ, OH, DE, MD, and theDistrict of Columbia, under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department ofHealth and Human Services. The contents do not necessarily reflect CMS policy. 12SOW-IPRO-QIN-TA-AA-20-41Check for updates. View our website for the latest version: https://neqpp.org/telehealth-rpm-guide

Table of ContentsTable of Contents . 2Who May Render or Bill for Telehealth? . 2Physician Office Telehealth Services (non-FQHC/RHC) . 3Physical, Occupational, Speech Therapy Telehealth Services (non-FQHC/RHC) . 6Facility Billing . 7Modifier CR . 7Telehealth in FQHC/RHC for Medicare Beneficiaries . 8Documentation . 9COVID-19 Coding ICD-10, HCPC, CPT . 10Remote Patient Monitoring – not billable in FQHC/ RHC . 12Resources . 14Who May Render or Bill for Telehealth? Physicians (MD, DO)Nurse practitioners (NP)Physician assistants (PA)Nurse-midwives (CNM)Clinical nurse specialists (CNS)Certified registered nurse anesthetists (CRNA)Registered dietitians or nutrition professional (RD, DSME)Physical, Occupational & Speech Therapists updated 4/30/2020Behavioral Health Specialistso Clinical psychologists (CPs)o Clinical social workers (CSWs)Other Highlights Providers may work cross-state lines regardless of licensure state. (See provider enrollment FAQs in resources)Services may be for all diagnoses; not just COVID-19OIG is allowing practices to reduce or waive fees or co-insurance (Also see CS modifier)Removal of E&M frequency limitations on Medicare Telehealth2

Physician Office Telehealth Services (non-FQHC/RHC)Modifier CS – COVID-19 Testing-related service. Waives deductible & co-insurance for testing-related services 3/1/20 to end of PHE. However, claims will notprocess at 100% payable until system update 7/1/2020 at which time NGS will reprocess all claims with CS modifier. Do not bill coinsurance or deduct to patientsfor testing –related services. Reopen claims to add this modifier if necessary.Modifier CR – Catastrophe-related service Informational on claims relevant to the PHE; eVisits, and on-line assessments. Not for use on claims for telehealth(audio-visual) services, or those services allowed prior to the Coivd-19 public health emergency (PHE). See more on page 6.Modifier 95 – Telemedicine modifier Add to all telehealth (audio and/or visual) services on the CMS list (see resources)Services Definition & CodesEvaluation and Management Visits – All Settings 99201 – 99205 office visits, new patient 99211 – Nurse/ MA visit 99212 – 99215 office visit established patient 99304 – 99306 NH/SNF Admission 99307 – 99310 NH/SNF Visits 99315 – 99316 NH/SNF Discharge 99324 – 99328 Assisted Living, new patient 99334 – 99337 Assisted Living, established patientFull list of telehealth CPT Information/Telehealth/Telehealth-CodesSeveral codes added, and several codes allowed for audio-onlyinteractions as of 4.30.2020Behavioral Health - May be rendered audio-only (phone oron-line without video). Bill with regular codes. (check full list) 90791 – Psychiatric evaluation90792 – Psych evaluation with med services90832 – 90838 psychiatric treatment w patient90839 – 90840 – Crisis treatment90845 – Psychoanalysis90847 – 90847 Family therapy w or w/o patient90853 – Group therapyNotes / Medicare Billing Use any private platform (i.e Skype, FaceTime, Zoom)New patient’s encounters are allowed via telehealth without regard tothe 3-year rule.Bill with usual designated location, i.e. office or clinic POS 11Modifier 95 (Modifier GT for CAH II, Modifier G0 for acute strokeservices). Do not report telehealth modifier for through-windowservices.POS 02 paid at the facility rate. POS where services are usuallyrendered will be paid at the full non-facility rate. May reopen claims toreprocess for increased payment.May add non Face-to-Face prolonged services to telehealth E&Ms.Billing archive/2020-03-31-mlnc-se POS where services are usually renderedIf rendered by telephone, bill the regular CPT service code, not thetelephone codes.Add CR modifier.Add 95 modifier when audio/visual or audio only3

Services Definition & CodesVirtual Check-Ins (per CMS Dear Clinician ar-clinicianletter.pdf CMS removed phone as a modality for G2012 June2020Notes / Medicare Billing Initiation by the patient; however, practitioners may need to educatebeneficiaries on the availability of the service prior to patient initiation.not related to a medical visit within the previous 7 days and does not lead to amedical visit within the next 24 hourspatient must verbally consent to receive virtual check-in servicesBilling provider only (not for nurse/MA visits).Podiatrists & Optometrists may bill.PT/OT/SPL may bill (with GN, GO, or GP modifier)Place of service (POS) is where physician usually provides services i.e. officeeVisits – new or established patientsOn-line digital E&M service (via on-line patient portal) 99421 – digital E&M service up to 7 days, cumulativetime; 5 to 10 minutes 99422 - digital E&M service up to 7 days, cumulativetime; 11 to 20 minutes 99423 - digital E&M service up to 7 days, cumulativetime; 21 or more minutes Billed every 7 daysPlace of service (POS) is where physician usually provides services i.e. officeAdd CR modifier. No modifier 95Telephone Services Physician (non-face-to-face) MD, DO,NEW – Physician telephone services may be billed to Medicare Part B whenrendered to patients in a Part A covered SNF stay. 8/3/2020. MACs will reprocessBrief communication service with practitioners via a number ofcommunication technology modalities (email, secure text,patient portal) including synchronous discussion over atelephone or exchange of information through video orimage. G2012 – virtual check-in, 5 to 10 minutes G2010 – remote evaluation of recorded images withinterpretation and follow-upNote: FQHC/RHC: G0071 – virtual check-in or remote evaluation ofrecorded images, 5 minutes or moreDPM, OD, DMD, DDS, NP, PA, CNM, CNS 99441 – telephone E&M, 5 to 10 minutes of medicaldiscussion99442 - telephone E&M, 11 to 20 minutes of medicaldiscussion99443 - telephone E&M, 21 to 30 minutes of medicaldiscussion claims for CPT codes 99441, 99442 & 99443 back to 3/1/2020, that were denied due toSNF CB edits. You do not have to do anything. If you already received payment from theSNF for these physician services, return that payment to the SNF once the MACreprocesses your claim. Established patient rule waived for COVID-19E&M Billing provider only may use these codesPlace of service (POS) is where physician usually provides services i.e. officeAdd modifier 95May add non-face-to-face prolonged service codes.Frequency limits removed for the PHE 6/16/2020 no more than one servicebillable per day. 98966 – 98968 are not included in frequency limit removal.4

Services Definition & CodesNotes / Medicare BillingTelephone Services Non-Physician (non-face-to-face) NP, PA, CNS, CNM, Psychologist, Physical/Occupational/SpeechTherapists, Optometry (OD), LCSW, Nutrition Professionals RD billregular dietician codes 98966 – telephone E&M, 5 to 10 minutes of medicaldiscussion98967 - telephone E&M, 11 to 20 minutes of medicaldiscussion98968 - telephone E&M, 21 to 30 minutes of medicaldiscussion Billed every 7 days. Add all phone call time together for each patient and billweekly.not related to a medical visit within the previous 7 days and does not lead to amedical visit within the next 24 hoursestablished patient rule waived for COVID-19Non-physician billing provider servicePlace of service (POS) is where clinician usually provides services i.e. officeAdd modifier CR (no modifier 95)May add non-face-to-face prolonged service codes.PT/OT/SPL bill with modifier GN, GO or GP Telephone Services Prolonged (nonF2F): 99358 - bill in additional to 99443 or 98969 for 31minutes to 1 hour of phone time 99359 – add to 99358 for 76 minutes or more Annual Wellness Visits – May now be rendered audio-only.Bill as AWV G0438 or G0439. G0438 – Annual Wellness Visit – initial G0439 – Annual Wellness Visit – subsequent G0444 – Annual depression screeningCheck in with Medicare beneficiaries to see how they are coping with thepandemic, monitor health status, provide referrals for food insecurity, depression/anxiety, and to support self-care.Perform the usual AWV componentsVital signs optional for PHESend copy of care plan to patientAdd modifier 95May perform acute visit if needed (add modifier 25 & 95).May not perform the initial IPPE via telehealthConsulting Physician Services Interprofessionaltelephone/internet/EHR assessment & management 99466 – 5 to 10 minutes 99447 – 11 to 20 minutes 99448 – 21 to 30 minutes 99449 – 31 minutesVerbal and written reportWritten report only, use 99451 (5 minutes) Use non face-to-face prolonged service codes for extended telephone timeover the day or 7-day period.add to either telephone code rangeadd CR modifierOther consultative services: 99452 - Treating physician or QHP (i.e. PCP) service, 30 minutes Usual telehealth (audio/visual) consults codes available, i.e G0425 – G0427;G0406 – G0408, G0508-G05095

Services Definition & CodesNeurostimulators & Analysis/Programming Procedures 95970 - Analysis of implanted neurostimulator pulsegenerator/ transmitter, without programming 95971 - Analysis of implanted neurostimulator pulsegenerator/ transmitter, with programming 95972 - Analysis of implanted neurostimulator pulsegenerator/transmitter; with complex spinal cord orperipheral nerve (eg sacral nerve) programming 95983 - Alys brn npgt prgrmg 15 min95984 Alys brn npgt prgrmg addl 15Notes / Medicare BillingAdded 10/14/2020Please see CPT code manual for full descriptionsPhysical, Occupational, Speech Therapy Telehealth Services (non-FQHC/RHC)Services Definition & CodesTherapy Services, Physical and Occupational Therapy, All levels bill CPT codes PT/OT Evaluations 97161- 97168 PT/OT Therapy 97110, 97112, 97116, 97535, 97750, 97755, 97760, 97761 SPL 92521- 92524, 92507PT/OT/SPL Therapists may also bill telephone services and these assessment codes to NGS:On-line assessment by qualified non-physician healthcare professional G2061 – On-line assessment for up to 7 days; 5 to 10 minutes G2062 - On-line assessment for up to 7 days; 11 to 20 minutes G2063 - On-line assessment for up to 7 days; 21 or more minutesCardiac Rehabilitation Services (added 10/14/2020) 93797 out-patient cardiac rehab, without continuous ECG monitoring (per session) 93798 out-patient cardiac rehab, with continuous ECG monitoring (per session) 93750 Interrogation of ventricular assist device (VAD), in personIntensive Cardiac Rehabilitation Services (added 10/14/2020) G0422 Intensive cardiac rehab, with or without continuous ECG monitoring; withexercise, per session G0423 Intensive cardiac rehab, with or without continuous ECG monitoring;without exercise, per session G0424 Pulmonary rehab with exercise (and monitoring), one hour, per session, upto two sessions per dayNotes / Medicare Billing Add modifier 95POS usually customaryPT/OT/SPL add GN, GO, or GP modifier May not include new patientsBill cumulative time every 7 daysPT/OT/SPL add GN, GO, or GP modifier must be audio and visual must be audio and visual6

Facility BillingFacility Fee – Q3014Billable by a facilitywhere the patient islocated.Provider-based Hospital CMS has said that a provider-based hospital may bill a facility fee for registered outpatients who receive servicesfrom home via telehealth. Use CR or DR modifier.Nursing Homes A staff member will need to facilitate the telemedicine experience between the patient and clinician by managingthe technology onsite at the nursing home. Nursing homes do not need to apply for a waiver to use telehealth and telemedicine services. Q3014 is not allowed in Skilled Nursing Facility type of bill 21X Q3014 is allowed on type of bill 22X or 23X – SNF Part B stay nce/Manuals/Downloads/clm104c07.pdfModifier CRWaiver/ FlexibilityDurable Medical Equipment,Prosthetics, Orthotics, and Supplies(DMEPOS)Modification of 60- Day Limit forSubstitute Billing Arrangements(Locum Tenens)Waivers of certain hospital andCommunity Mental Health Center(CMHC) Conditions of Participation andprovider-based rulesSummaryWhen DMEPOS is lost, destroyed, irreparably damaged, or otherwise rendered unusable, allow theDME Medicare Administrative Contractors (MACs) to have the flexibility to waive replacementsrequirements such that the face-to-face requirement, a new physician’s order, and new medicalnecessity documentation are not required. Suppliers must still include a narrative description on theclaim explaining the reason why the equipment must be replaced and are reminded to maintaindocumentation indicating that the DMEPOS was lost, destroyed, irreparably damaged, or otherwiserendered unusable or unavailable as a result of the emergency. Add modifier CR to HCPCModifies the 60-day limit to allow a physician or physical therapist to use the same substitute for theentire time he or she is unavailable to provide services during the COVID-19 emergency, plus anadditional period of no more than 60 continuous days after the public health emergency expires. Onthe 61st day after the public health emergency ends (or earlier if desired), the regular physician orphysical therapist must use a different substitute or return to work in his or her practice for at leastone day in order to reset the 60-day clock. Physicians and eligible physical therapists must continueto use the Q5 or Q6 modifier (as applicable) and do not need to begin including the CR modifieruntil the 61st continuous day.Allows a hospital or Community Mental Health Center (CMHC) to consider temporary expansionlocations, including the patient’s home, to be a provider-based department of the hospital orextension of the CMHC, which allows institutional billing for certain outpatient servicesfurnished in such temporary expansion locations. If the entire claim falls under the waiver, theprovider would only use the DR condition code. If some claim lines fall under this waiver and othersdo not, then the provider would only append the CR modifier to the particular line(s) that falls underthe waiver.7

Waiver/ FlexibilityBilling Procedures for ESRD serviceswhen the patient is in a SNF/NFClinical Indications for CertainRespiratory, Home AnticoagulationManagement, Infusion Pump andTherapeutic Continuous GlucoseMonitor national and local coveragedeterminationsSummaryIn an effort to keep patients in their SNF/NF and decrease their risk of being exposed to COVID-19,ESRD facilities may temporarily furnish renal dialysis services to ESRD beneficiaries in the SNF/NFinstead of the offsite ESRD facility. The in-center dialysis center should bill Medicare using ConditionCode 71 (Full care unit. Billing for a patient who received staff-assisted dialysis services in a hospitalor renal dialysis facility). The in-center dialysis center should also apply condition code DR to claimsif all the treatments billed on the claim meet this condition or modifier CR on the line level to identifyindividual treatments meeting this condition.In the interim final rule with comment period (CMS-1744-IFC and CMS-5531-IFC) CMS states thatclinical indications of certain national and local coverage determinations will not be enforced duringthe COVID-19 public health emergency. CMS will not enforce clinical indications for respiratory,oxygen, infusion pump and continuous glucose monitor national coverage determinations and localcoverage determinations. Add CR modifier to these claims.For the full listing of CR/DR modifier usage, click here health in FQHC/RHC for Medicare Beneficiaries(i)the Secretary shall pay for telehealth services that are furnished via a telecommunications system by a Federally qualified health center or a rural health clinic to an eligibletelehealth individual enrolled under this part notwithstanding that the Federally qualified health center or rural clinic providing the telehealth service is not at the same locationas the beneficiary;Please see next page.Services Definition & CodesTELEHEALTH SERVICE—(i) IN GENERAL—The term “telehealth service” meansprofessional consultations, office visits, and office psychiatryservices (identified as of July 1, 2000, by HCPCS codes 99241–99275, 99201–99215, 90804–90809, and 90862 (and assubsequently modified by the Secretary)), and any additionalservice specified by the Secretary.(ii) YEARLY UPDATE.—The Secretary shall establish a processthat provides, on an annual basis, for the addition or deletion ofservices (and HCPCS codes), as appropriate, to those specified inclause (i) for authorized payment under paragraph (1).(F)Full list of telehealth CPT codes nformation/Telehealth/Telehealth-CodesNotes / Medicare BillingThrough 6/30/2020FQHC Encounter G code ie. G046/67/69/70 telehealth list CPT code with 95 modifier G2025 95 modifierRHC telehealth list CPT code with CG and 95 modifier G2025 CG modifierAs of 7/1/2020FQHC G2025 (no

Oct 14, 2020 · Cardiac Rehabilitation Services (added 10/14/2020) 93797 out-patient cardiac rehab, without continuous ECG monitoring (per session) 93798 out-patient cardiac rehab, with continuous ECG monitoring (per session) 937

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