Telehealth COVID-19 Coding & Billing Updates
Due to the recent outbreak in COVID-19 paired with increased concern for patients to be seen under quarantine conditions, Welter Healthcare Partners is striving to collect all relevant documentation, coding and billing details to help clinicians assure they receive appropriate reimbursement for unique services they are providing. Welter Healthcare Partners recommends checking with your top payors for coverage benefits, limitations and originating site waivers. Your feedback is greatly appreciated. Welter Healthcare Partners will continue to provide updates as we receive them. If you have any questions, please contact us at info@rtwelter.com. nnThe CPT Editorial Panel approved a new CPT® code at a special, expedited meeting held, via telephone, on Friday, March 13, 2020. A new CPT® code has been created that streamlines novel coronavirus testing offered by hospitals, health systems, and laboratories in the United States. nnNEW CPT CODE: 87635 Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique. nnCPT Assistant has provided a fact sheet for coding guidance for the SARS-CoV-2 (COVID-19) test in relation to the use of the new CPT code. Click here for the fact sheet.nnThere are two new HCPCS codes for healthcare providers who need to test patients for Coronavirus. Providers using the Centers for Disease Control and Prevention (CDC) 2019 Novel Coronavirus Real-Time RT-PCR Diagnostic Test Panel may bill for that test using the newly created HCPCS code (U0001). A second new HCPCS code (U0002) can be used by laboratories and healthcare facilities to bill Medicare as well as by other health insurers that choose to adopt this new code for such tests. HCPCS code (U0002) generally describes 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19) using any technique, multiple types or subtypes (includes all targets). The Medicare claims processing system will be able to accept these codes on April 1, 2020 for dates of service on or after February 4, 2020. Click here for more information.nnTelehealth Evaluation considerations: nnEffective immediately 03/14/2020, United Health Care (UHC) will wave CMS originating site restrictions for Medicare Advantage, Medicaid and commercial members so services can be performed while the patient is in their home, effective until April 30, 2020. United Health care has waived all member cost-sharing, including copays, coinsurance, and deductibles, for COVID-19 diagnostic testing provided at approved locations, in accordance with the Centers for Disease Control and Prevention (CDC) guidelines for all commercial insured, Medicaid and Medicare members. UHC will also reimburse providers for telephone calls to existing patients. nnWe’ve found that most payors advise providers billing telemedicine to use the appropriate evaluative and management CPT code (99201 – 05, 99211-15) along with a GT modifier. nAlthough, MM10152 from January 1, 2018 eliminates the requirement of the use of GT modifier on professional claims. Click here for more information.nnPrivate payors may prefer that you use the telemedicine specific code 99444. It varies based on the payer and the state guidelines.nnMany of the MACs have yet to loosen the reigns on the originating site requirement with the use of “02” Place of Service with an office visit code. There are many other payors, including Medicare Advantage plans that have waived the originating site requirement. nnCMS is recommending the use of G2012 for telehealth services in a recent press release: nnCode G2012 has specific guidelines and documentation requirements to keep in mind when considering the appropriate use of this code: nnG2012 (Brief communication technology-based service, e.g. 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 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; 5-10 minutes of medical discussion).nnReimbursement according to the recent MFS is $14.89.n
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- The service is communication technology-based
- The provider can be a physician or other qualified health care professional who reports E/M services
- Interaction must be between the patient and billing practitioner, not clinical staff.
- The communication can’t be related to an E/M service from within the previous seven days.
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- The communication can’t lead to an E/M service within 24 hours (or soonest available): The language in the code descriptor states, “nor leading to an E/M service or procedure within the next 24 hours.” Consequently, Medicare will be watching for an uptick in appointments occurring 25 hours or so after the call. Do not game the system to get around the 24-hour limitation.
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- The code represents five to 10 minutes of medical discussion.
- The medical record must document verbal consent from the patient for each billed service. Cost-sharing applies, and the beneficiary co-payment isn’t waived.
- The service is available only to established patients, defined as patients who have “received professional services from the physician or qualified health care professional or another physician or qualified health care professional of the exact same specialty and subspecialty who belongs to the same group practice, within the past 3 years.”
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nHealth First of Colorado states, “Place of Service 02 should be used to report services delivered via telecommunication, where the member may be in their home and the provider may be at their office.” nnNon-F2F evaluation & management telephone services 99441-99443 may also be a consideration. This category of codes have yet to be recognized as CMS for reimbursement. Many other payors also do not cover these services. Welter Healthcare Partners recommends verifying coverage, limitations and reimbursement with your top payers for these services. nnModifier Considerations: nnUse of GT modifier on Medicare claims was eliminated in 2018. According to CMS, the place of service code 02 is sufficient. See the instructions below for appropriate consideration of CR modifier. nnChange Request (MLN) MM10152 from January 1, 2018 eliminates the requirement to use the GT modifier (via interactive audio and video telecommunications systems) on professional claims for telehealth services. Use of the telehealth Place of Service (POS) Code 02 certifies that the service meets the telehealth requirements. Click here to read the request.nnEffective August 31, 2009, the use of the CR modifier will be mandatory for applicable HCPCS codes on any claim for which Medicare Part B payment is conditioned directly or indirectly on the presence of a “formal waiver.”nnThe CR Modifier: Both the short and long descriptors of the CR modifier are “catastrophe/disaster-related.” The CR modifier is used in relation to Part B items and services for both institutional and non-institutional billing. Non-institutional billing, i.e., claims submitted by “physicians and other suppliers”, are submitted either on a professional paper claim form CMS-1500 or in the electronic format ANSI ASC X12 837P or – for pharmacies – in the NCPDP format. In previous emergencies, use of the CR modifier was entirely discretionary with the billing provider or supplier. It no longer may be used at the provider or supplier’s discretion. Effective August 31, 2009, the use of the CR modifier will be mandatory for applicable HCPCS codes on any claim for which Medicare Part B payment is conditioned directly or indirectly on the presence of a “formal waiver.”nnSee the MLN in its entirety for appropriate consideration of the CR Modifier here.nnDiagnosis (ICD10COM) Coding for COVID-19: Interim coding advice for COVID-19 has been provided by the CDC here. Clinicians are reminded to follow HIPAA mandated diagnosis coding guidance by reporting signs or symptoms until a definitive diagnosis has been made. nn nn
In March 2020, The U.S. Department of Health and Human Services finalized two HHS interoperability rules that give patients access to their healthcare data. With this new system, patients and providers will be able to access their medical records through applications on smartphones. While these new rules sound like a big step forward for the healthcare industry, there have been mixed reviews as some people are worried about patient privacy and provider API cost. Read the article below to find out more about this interesting development. nnThe U.S. Department of Health and Human Services (HHS) has finalized two interoperability rules to give patients direct access to their healthcare data. The first provisions of the rule will impact healthcare systems in as soon as six months.nnThe two rules, issued by the HHS Office of the National Coordinator for Health Information Technology (ONC) and Centers for Medicare & Medicaid Services (CMS), were announced last year, and the final rules were issued today. They are expected to “empower patients around a common aim—giving every American access to their medical information so they can make better healthcare decisions,” according to a release issued by CMS.nn”Americans will now have electronic access to their health information on their smartphone if they choose,” said ONC National Coordinator Don Rucker, MD, during a White House media briefing this morning with multiple government officials. “Our rule requires hospitals and doctors to provide software access points—endpoints if you will—to their electronic medical record databases so that patients can download these records to their smartphones.”nnOne key deadline for health systems occurs six months from today, said CMS Administrator Seema Verma. “We are changing the conditions of participation for hospitals to ensure Medicare- and Medicaid-participating hospitals are supporting care coordination for patients by sending admission, discharge, and transfer notifications so patients receive a timelier follow up, supporting better care and better health outcomes,” she said.nnThe CMS rule also impacts payers. Starting in 2021, Verma said, “all health plans doing business in Medicare, Medicaid, CHIP, and the federal exchanges [must] share their health data with their patients through a secure standards-based API (application programming interface), which represents the link between the data on various systems and [the] consumer’s phone.”nnThe rule also requires payers to make their provider directories publicly accessible through a provider directory API starting in 2021, said Verma. “This will allow innovative third parties to design apps that will help patients evaluate which plan networks are right for them and potentially avoid surprise billing by having a clearer picture of which clinicians are in-network,” she said.nnHHS Secretary Alex Azar said he expects the rules to spawn a new era of innovation in healthcare. “We hope to see a whole ecosystem of condition- or disease-specific apps to help patients monitor and improve their health in real-time, in part, by using data made available from their electronic health record via an API,” said Azar.nnRucker further commented: “We’re going to see a growth in patient-facing healthcare IT markets from an entirely new app ecosystem that’s going to be fueled by transparency about both product and price. We think this health app economy is going to have new services and we see the smartphone—not just as a smartphone—but as a tool to connect other devices to it.”nnAs expected, the ONC rule specifies the API certification criterion requires the use of the Health Level 7 (HL7) Fast Healthcare Interoperability Resources (FHIR) standard Release 4 and references other standards and implementation specifications to support standardization and interoperability.nnPatient Privacy ConcernsnThe ONC rule received more than 2,000 comments from the public, said Rucker. While most pertained to price transparency, concerns about protecting patient privacy rose to the forefront when Verona, Wisconsin, EHR vendor Epic Systems launched an initiative to delay the ONC ruling until certain patient privacy issues were addressed. The company marshaled its health system clients to write a letter to Azar to request the delay.nnDuring the White House media briefing with reporters, Azar said, “I want to emphasize that we’re taking these actions while maintaining and strengthening patient privacy protections. Patient privacy should never stand in the way of patient control.”nnIn a later media briefing on Monday exclusively with ONC representatives, Rucker said the final rule does not offer explicit mandates for third-party app privacy requirements, in part, for legal reasons.nn”Under the HIPAA right of access, [access to your] data is your right,” said Rucker. “We cannot, as a general matter, of course, presume to tell you how you are going to exercise your rights to your data.”nnIn addition, he said that while the U.S. Food & Drug Administration has some regulatory control over consumer apps, the ONC does not want to institute measures that will stifle innovation so early in the app development process. “The future is really unbounded, and we do not want to prospectively clamp off business models … We should really be open to the opportunities, um, that modernity affords us.”nnIn a statement issued Monday to HealthLeaders, Epic said, “The rule is very important to health systems and their patients, so we will read it carefully to understand its impact before making judgments.” In Epic’s statement today, among the issues it said it would closely scrutinize was “transparency for patients into companies’ data use and data handling practices.”nnYet the American Hospital Association still has concerns. In a statement issued after the final rule was released, the organization said, “America’s hospitals and health systems support giving patients greater access and control over their health data … However, today’s final rule fails to protect consumers’ most sensitive information about their personal health. The rule lacks the necessary guardrails to protect consumers from actors such as third-party apps that are not required to meet the same stringent privacy and security requirements as hospitals. This could lead to third-party apps using personal health information in ways in which patients are unaware.”nnIndustry ReactionnThe news received mixed reviews by healthcare systems, healthcare organizations, and observers, but most had not yet had the opportunity to completely review the 1,244-page ONC final rule or the 474-page CMS rule.nnAmong the misgivings expressed:n
CMS has released a second emergency code for the testing of CORVID-19. To find out more about this update, read the article below and click on the links to see how you are covered. nnAs of Friday, March 6th, CMS released a second emergency code for CORVID-19 testing. Unlike HCPCS code U0001, which was released last month, U0002 will be used by laboratories to bill for non-CDC SARS-CoV-2/2019-nCoV (CORVID-19).nnHCPCS code U0001 was enacted to bill for tests and to track new cases of the virus. CMS and Medicare claim processing systems will begin accepting these codes as of April 1st for dates of service on or after February 4th of this year.nCheck with individual payers for guidance based on your contracts with them.nnCMS has also released three different fact sheets related to the virus. Click on the links below for more information regarding these updates from CMS:nn
Anthem has recently finalized its acquisition of Beacon Health. This deal will allow for the expansion of critical behavioral health services, which will provide more care across the country. Read the article below for more information regarding the new changes that will come to Beacon and Anthem.nnAnthem, Inc. on Monday said it has finalized its previously announced acquisition of Beacon Health Options, the nation’s largest independently held behavioral health organization.nnFinancial terms were not disclosed for the sale of Boston-based Beacon, which had been held by Bain Capital Private Equity and Diamond Castle Holdings. The newly acquired BHO will move into Anthem’s Diversified Business Group.nnBeacon serves 36 million people and almost 3 million individuals in comprehensive risk-based behavioral programs. Indianapolis-based Anthem said the acquisition creates an opportunity to combine existing behavioral health capabilities “with Beacon’s successful model and support services in order to enhance whole-person care.”nn”We are pleased to complete the acquisition of Beacon Health Options and are excited to expand our critical behavioral health services to more people across the country as part of our focus on true whole-person care,” Anthem CEO Gail K. Boudreaux said in a media release.nn”Consumers and health plan customers alike will benefit from our ability to scale and integrate physical and behavioral capabilities in new and meaningful ways to improve lives,” she said.nnWhen the deal was first announced last June, Beacon CEO Russell C. Petrella said the acquisition would provide Beacon will scale to expand service options.nn”Together, we will expand access and enhance the quality of care for our mutual members,” Petrella said in a statement. “I am proud of the talented and committed team at Beacon, and we look forward to our future with Anthem.”nnOriginal 
When we go to the doctor, someone puts notes into our file. If you see these notes, some entires might be strikingly similar. This is called cloned notes. Below in this week’s Industry Hot Buttons, we go over cloned notes and how they can be an issue. Read the article below to find out more!nnCloned notes, as defined by CMS, are entries in a patient’s health record that are identical or strikingly similar to other entries in the same or another patient’s health record.nnEMR’s have made the lives of health industry professionals easier in so many ways. Unfortunately, they have also created a few headaches.nnMany people may not have known him until his recent passing, but Lawrence “Larry” Tesler was one of the computer scientists who created the “copy/paste” function.nnThis function has completely changed the way that each of us uses technology every day and is a function some of us would be lost without, myself included.nnThe problem is when this is over-utilized in the medical record. It leads to contradictions in our notes, unnecessary information, and often times the needed and pertinent information is left out.nnAs far back as 2013 the OIG has had Cloned Notes on their radar. It can lead to loss of integrity of the documentation and even damage the trustworthiness of the clinicians.nnIn a recent issue of 
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