Your telehealth reimbursement questions, answered

Physicians need telehealth to ensure they can treat their patients during this unprecedented COVID-19 pandemic. They also need to secure the necessary revenue to keep their practices functioning through accurate coding and documentation.

So how can physicians ensure they get paid for telehealth visits?

Since the beginning of the COVID-19 pandemic, Medical Economics® has received many questions from physicians on how to properly code and document telehealth visits. To answer your questions, we reached out to health care business consultant Elizabeth W. Woodcock, MBA, FACMPE, an expert on coding and documentation. The following interview has been edited for length and clarity.

Medical Economics®: Where can physicians go to get the most correct, up-to-date information for telehealth coding and documentation?

Woodcock: It’s a great question. And we’re hampered by two details that are incredibly frustrating. First of all, almost every payer has its own nuances, its policy protocols related to coding reimbursement. And second of all, those are changing what seems like every day. So if you’re frustrated, you’re not the only one. I am, too. However, it appears that we are now at a ... sustainable state, meaning (the rules have been) worked out and as of today, you pretty much know what they are going to be.

ME: We received a lot of questions about whether you can be reimbursed via telehealth for phone calls that don’t use video.

Woodcock: On April 30, CMS actually made audio-only telemedicine possible. Prior to that, they had held steady to audio and video being required. But (that April 30 ruling) was actually retroactive back to the beginning of the public health emergency. Indeed, audio is now applicable. And so physicians can bill the telephone-only codes and, interestingly enough, receive reimbursement at the level of an outpatient visit. So it’s exciting to have had that change.

ME: That’s Medicare we’re talking about, correct?

Woodcock: That’s a great point. Yes, this is Medicare. And indeed, just like we discussed early on, because each payer has different policies, it pays to check with your particular payers to see if they allow phone-only telemedicine visits.

ME:We have received a lot of questions about modifier “CS.” Can you explain what that is and what physicians need to know to get paid for using it?

Woodcock: “CS” is a relatively new modifier that was brought about based on a law passed by the federal government and includes all payers. So this is not just a Medicare issue. All private payers did agree to this — not to the particular use of the modifier but to the fact that physicians will be reimbursed at 100% of the allowable if a COVID-19 test is administered or ordered during the encounter. There’s a bit of nuance in that the law says: If the encounter is for the evaluation of (whether) a test (needs) administered or ordered, that counts too.

So what do you do? For Medicare patients, use modifier “CS.” ... It’s a payment modifier that triggers 100% of the allowable. And because it’s a payment modifier, it needs to go on right after the CPT code. So for example, if you see a patient and it’s a level-three established patient, visit (99213) and you ordered a COVID-19 test, you want to put the “CS” modifier in the documentation. And what that means is your Medicare contractor will pay you at 100% of the allowable. It’s important to recognize, and this is a great payment tip, that you can actually go back to March 18 to use this modifier. Most of our Medicare contractors are requiring these claims be resubmitted. But you can go back to March 18 and resubmit them with the “CS” modifier to get paid at 100%. For other payers, they’re all obligated to do this, but you do need to check with them with regard to the policy about coding.

ME:What’s the best way to check with private payers? Are they updating physicians on a regular basis, or do you need to pick up the phone and contact the payer?

Woodcock: I wish we could pick up the phone and contact any payer, but that’s an impossible task because they don’t have phone numbers any longer. However, they’re certainly issuing memoranda. We are seeing that it’s actually on their websites. Most of them have a COVID-19 or a public health emergency resource page. So that’s probably the best bet. Unfortunately, Plan B is to go ahead and submit the claim and then get the denial.

ME:This was maybe the most frequent question we received in regard to telehealth: What are the current rules regarding “place of service”? And what do you need to do to ensure that you’re receiving the best possible reimbursement?

Woodcock: When the public health emergency was declared, CMS said, “Let’s go ahead and use a telehealth ‘place of service 02.’” So all of us were scrambling. And there was correspondence and communication coming out that physicians would be paid at the regular rate, except that the “02” modifier triggered a lower facility rate. I won’t go into the details, other than saying physicians were getting paid less. So CMS came out and said to replace the “02” with whatever “place of service” you would have used if that patient encounter had been face to face. And so, even though this is frustrating, I would argue that CMS was actually doing the right thing by saying, “Listen, we know this is triggering a lower reimbursement. We want doctors to get paid what they should. So if you would have been billing as a ‘place of service 11,’ which is a physician’s office, then please go ahead and continue to do that.” It was a great strategy. Even though it’s frustrating from a payment perspective, it really was the best thing to do.

ME:The next question asks about the G2012 code and whether it can be used for follow-up phone calls after a telemedicine visit. Can you talk a little bit about what’s allowed in terms of that “G” code and following up?

Woodcock: So the “G” code pays about $15 but does indeed require you to get outside of a seven-day window, so it cannot be used for services that originate from an “evaluation and management (E/M)” service that was provided. So if you call the patient two or three days later, the E/M code ... incorporated your reimbursement. But if you’re calling them nine days later or you’re just checking in with them, then that would certainly count as G2012. Again, about a $15 reimbursement. Now if you’re remote patient monitoring, another set of higher paying codes fall under that topic.

ME:Could you expand on those remote patient-monitoring codes?

Woodcock: Absolutely. Let’s say you have a patient who tested positive or negative for COVID-19, and you’re worried about them. So you’re basically checking in with them — you’re remote patient monitoring because (they’re not) coming into the office. ... There are multiple codes in that series. And they can be billed in units of time, and those units are in 20 minutes.

ME:What is modifier “95,” and how does it work?

Woodcock: Modifier “95” is the telehealth modifier Any time you conduct telehealth, be sure to add modifier “95.” It’s really an information-only modifier, so it doesn’t trigger a different kind of payment. It’s really meant for researchers to track on the back end and for CMS to know what type of visit you’re rendering. ... Let me just mention again that it’s with “place of service 02” and modifier “95” that we’re seeing a variation in terms of some payers asking for the “02” and some payers asking for the “95.” There’s also this crazy modifier called a “GT” that was kind of an old telemedicine modifier. Unfortunately, some payers are asking for that as well.

ME:So again, it’s important to check with your payers to see what they’re requiring to ensure you’re using the right modifiers to get paid.

Woodcock: Absolutely.

ME:Here’s another technical question about modifiers: Can you use modifier “95” and “CS” at the same time?

Woodcock: You absolutely can. But because “95” is informational only, I’m going to use that in a secondary position. “CS” should go in the primary position because it triggers a different payment.

ME:Can you use modifier “CS” if a patient is evaluated for COVID-19, but then no testing is ordered. Is testing a required part of that?

Woodcock:would ask that our physicians really review that law. It’s my interpretation that it certainly can be evaluation only. I am seeing some payers be very specific about — you have to have the COVID-19 test ordered or administered for that encounter. I do want to mention that this is actually not just the encounter. So if the physician, for example, orders a flu test in addition to the COVID-19 test during the course of this encounter, those are also indeed covered at 100%. I didn’t want to forget that nuance. It’s important.

ME:In terms of technical glitches with telehealth, one of the questions we received was if a telehealth call is interrupted and essentially can’t continue because of a software glitch or some internet connection issue, how do you handle the billing?

Woodcock: The best way to handle this is to just default to a telephone-only code, which a few months ago would have meant a plunge in reimbursement. But now, it’s the same thing as a “99212,” “99213” and “99214,” respectively. So there are three telephone codes that now pay at the same rate as in-person visit.

ME:Is there anything else in regard to telehealth billing, coding or documentation that you think is important for physicians to keep in mind?

Woodcock: I know this is frustrating and at times overwhelming, but it does represent a new normal. So I do think it’s a great opportunity. (It takes) time to really learn these rules related to telemedicine, (but) I think it’s time well invested. All the data are showing us that ... patients are going to have an incredible amount of hesitancy about physically going to the physician office again. So it’s a great time to learn about this.