Telehealth: Billing & Workflow Recommendations

If your practice is exploring alternative methods to remotely check-in with your patients and evaluate their health, there are a number of telemedicine services that may be reimbursable by CMS and private payers. CMS specifically categorizes virtual services into 4 groups: telehealth visits, virtual check-ins, eVisits, and (new) telephone-only E/M.

In this article, we will cover the differences between each of these telemedicine services and how to bill for them.
 

Contents

• Telehealth Billing Decision Tree
• Telehealth waivers in place due to the COVID-19 public health emergency
• Setting up your Elation account for telehealth
• Setting up your integrated billing system for telemedicine
• Types of virtual services
  • Telehealth Visits
  • Virtual Check-ins
  • eVisits
  • Telephone-Only E/M
• Additional Resources from CMS

Telehealth Billing Decision Tree 

Telehealth waivers in place due to the COVID-19 public health emergency

The government has expanded Medicare’s telehealth benefits under the 1135 waiver authority, the Coronavirus Preparedness and Response Supplemental Appropriations Act, the Coronavirus Aid, Relief, and Economic Security (CARES) Act and CMS’ Interim Final Rule.

What does this mean for you?

• Telehealth requirements for originating/distant site status of the physician and beneficiary waived. Historical restrictions that prevented clinicians from being paid except under certain circumstances (ex. a patient must be from a rural area and present at an approved facility as the “originating site” of service) have now been lifted. 
• Telehealth reimbursement increased to be on par with in-person services. As long as the COVID-19 Public Health Emergency (PHE) is in effect, clinicians can bill for telehealth services provided for dates of service starting March 6, 2020. Telehealth services are paid under the Physician Fee Schedule for the same amount as in-person services as long as the proper coding is submitted. See billing guidance below for more information about how to bill for facility vs. non-facility rates.
  • User Tip: These policies are based on CMS standards. Always double check with the policies designated by other Payers to ensure you are following their coding guidelines for telehealth services.
• HIPAA regulations loosened. The government is now allowing clinicians to use everyday technology (FaceTime, Skype, etc.) to interact with patients during the Public Health Emergency, in good faith that practices will continue to exercise caution under HIPAA.*
• Out-of-state providers do not need to be licensed in the state where they are providing services if they are licensed in another state.* 
• Telehealth and virtual check-in services can be provided to new patients. To the extent that the 1135 waiver requires an established relationship, the HHS will not conduct audits to ensure that a prior relationship existed for claims submitted for telehealth visits during this public health emergency. Virtual check-ins may now be completed for new patients as opposed to only established beneficiaries. Note that the same does not apply to eVisits.
• Remote staff supervision allowed. Clinicians can supervise staff members virtually instead of needing to be on-site.
• New telephone/audio-only E&M codes are now reimbursable by CMS. For the duration of the COVID-19 Public Health Emergency, CMS will be reimbursing care provided via phone/audio-only using the following newly accepted CPT® codes: 98966-98968 for qualified non-physicians and 99441-99443 for physicians. These codes allow for a greater amount of time spent to be coded for at a higher reimbursement rate than the existing G2012 telephone-only code. 

*Additional information applicable to the above waivers: 

• The above updates apply to CMS Medicare FFS beneficiaries. Private payers may have specific coding requirements for telehealth, and states may have their own rules and regulations. Contact your state’s department of health or payer to confirm state- or payer- specific requirements.
• During the COVID-19 public health emergency, some states and payers are allowing telemedicine services to be provided via audio only/telephone. An example of this is California - where the Department of Managed Health Care released an all payer letter (and this follow up letter) stating that audio visits will be reimbursed the same as in-person E&M, provided requirements are met for care delivery. Contact your state’s department of health or payer to confirm state-specific requirements.
• States may have their own requirements protection of healthcare data and licensure requirements.

Setting up your Elation account for telehealth

To learn more about how you can use Elation to deliver care for your patients through telemedicine with minimal disruption to care delivery and to the financial health of your practice, please see our step-by-step guide here. This guide covers how to complete a patient encounter through telemedicine and how to set-up your Elation account to support this.

Below are several quick set-up steps that you can take in your Elation account today so that you can begin seeing patients and billing for telehealth services:

Setting up your integrated billing system for telemedicine

Our team has created resources that will guide you through the necessary settings page updates to bill for telehealth. Each guide linked below provides detailed step-by-step instructions to ensure that your practice can successfully send telehealth charges from Elation to your integrated practice management system (PMS).  

• Kareo
• Akamai
• CollaborateMD
• Practice Suite
• ConnxtMD
• AdvancedMD
• HealthBiller

Types of Virtual Services

Breakdown of Virtual Service Types & Requirements


 

Telehealth Visits

Telehealth visits are full-visits which require audio-visual, real-time, two-way interactive communication systems. Out of the three types of virtual services covered in this help center article (telehealth, virtual check-ins, eVisits), telehealth visits typically provide the highest reimbursement rate for Medicare/Medicaid. You can use Elation's HIPAA-compliant, integrated video feature powered by Zoom to complete your telehealth visits. See table above for additional requirements of Telehealth Visits.

Virtual Check-ins

Virtual Check-ins are reimbursable services for brief communications between providers and patients for specific purposes. These services are not restricted by originating site and other Medicare telehealth regulations. They can be provided when patients are in their homes, regardless of public health emergency declaration. These services can be rendered via telephone, email, or Elation’s Patient Passport. 

While Virtual Check-ins must be patient initiated, providers can let patients know that they can reach out through this method to receive care, and patients may agree to change a previously scheduled face-to-face visit to a virtual encounter. Time spent should be documented in the note, and information that can be stored and shared should be stored in the patient’s electronic health record.  See table above for additional requirements of Virtual Check-ins.

Billable codes and CMS Physician Fee Schedule Non-Facility estimated prices are listed below. Please note that these reimbursement rates may differ based on your locality for Medicare. Please check your health plan provider network representative for accepted codes and contracted rates, as coding requirements may differ by payer.

eVisits

eVisits are reimbursable services that occur between an established patient and their provider through an online HIPAA-compliant portal, like Elation Passport. These services are not restricted by originating site and other Medicare telehealth regulations. They can be provided when patients are in their homes, regardless of public health emergency declaration.  

eVisits must include clinical decision making and evaluation, assessment and management that would have otherwise been provided in the office. Simply responding to the portal or secure email messages does not qualify as a billable service. 

While eVisits must be patient initiated, providers can let patients know that they can reach out through this method to receive care, and patients may agree to change a previously scheduled face-to-face visit to a virtual encounter. Time spent should be documented in the note, and information that can be stored and shared should be stored in the patient’s electronic health record.  See table above for additional requirements of eVisits.

Billable codes and CMS Physician Fee Schedule Non-Facility estimated prices are listed below. Please note that these reimbursement rates may differ based on your locality for Medicare. Please check your health plan provider network representative for accepted codes and contracted rates, as coding requirements may differ by payer.
 

Telephone-Only E/M

Telephone-only E/M codes are newly reimbursable services (for the extent of the COVID-19 public health emergency only) that occur between a patient and their provider through an audio-only/telephone call. The codes require assessment and management of a problem over the phone and require medical necessity to be billable. These codes allow for a greater amount of time spent to be coded for at a higher reimbursement rate than the existing G2012 telephone-only code for a Virtual Check-in. See table above for additional requirements of these telephone-only E/M codes.

Under CMS’ interim final rule, Medicare is also extending the definition of qualified non-physician practitioner for the CPT codes 98966-98968 to include LCSWs, clinical psychologists, physical therapists, occupational therapists, and speech language pathologists -- when the visit pertains to a service within the benefit category of those practitioners. These telephone E/M services may also be provided to family/guardians of Medicare beneficiaries, regarding the care of the beneficiary. 

Billable codes are listed below. Please check your health plan provider network representative for accepted codes and contracted rates, as coding requirements may differ by payer.

CPT copyright 2022 American Medical Association. All rights reserved.
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Additional Resources from CSM

• 2022 Medicare Physician Fee Schedule Final Rule
• New/Modifications to the Place of Service (POS) Codes for Telehealth
• AMA special coding advice during COVID-19 public health emergency
• COVID-19 Frequently Asked Questions on Medicare Fee-for-Service Billing

Related Articles

• Adding Patient Tags
• Automated Appointment Reminders
• Getting started with Patient Passport
• How to set up Patient Invoicing
• How to set up your Elation Calendar
• How to set up your Patient Booking Site
• Elation Integrated Video- Connecting with patients using video
• Visit Note Types