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Telemedicine

Billing for telemedicine services

It’s important to understand the documentation requirements for telehealth, evisit, telephone only E/M etc billing to avoid denials in the future. Make sure you understand documentation requirements well and instruct your providers accordingly.

Hopefully you understand what you can bill for. If not, please review this post again.

It’s important to understand the telemedicine documentation requirements to avoid denials in the future. Make sure you instruct your providers accordingly as well.

New patient 99202 – what you need to document

Providers need to document for new patients

This needs ALL 3 components: 

  • An expanded problem focused history
  • An expanded problem focused examination
  • Straightforward medical decision making

Here’s a scenario for an ophthalmology practice

  1. Chief complaint
  2. 1-3 elements of HPI
    1. Location 
    2. Timing
    3. Context 
    4. Quality
    5. Modifying factor 
    6. Severity
    7. Duration 
    8. Associated signs and symptoms
  3. System in the HPI (history of present illness)
  4. If medically necessary (if you do document it, this helps your group’s MIPS reporting next year)
    1. Past history
    2. Family history
    3. Social history
  5. EXAM. Six to eight of the following 12 elements of the exam are performed
    1. Visual acuity – possible
    2. Ocular adnexa – possible
    3. Lens – not possible
    4. Confrontation visual fields  — possible. (Can be done with family member)
    5. Pupil and iris
    6. Intraocular pressure  — not possible.
    7. Extraocular motility — possible.
    8. Cornea – possible
    9. Optic nerve discs – not possible
    10. Conjunctiva – possible
    11. Anterior chamber — generally not possible
    12. Retina and vessels – not possible
  6. MDM (Medical decision making)
    1. Diagnosis
    2. ICD10 –  highest level of specificity please. Even if you have to add one each for OD OS, do it please.
    3. MUST HAVE ONE
      1. New problem to examiner: stable, improved or worsening
      2. Clinical lab test(s): ordered or reviewed
      3. Radiology tests: ordered or reviewed
      4. Other diagnostic tests: ordered or reviewed
      5. Review of old records and/or additional history from other than the patient. This generally means information gathered from sources other than the history and physical – lab tests, imaging, other diagnostic services, old records and history from sources other than the patient. Generally speaking, the guidelines ask that you record the decision to seek additional information and, if you have obtained the information, the results of your review of it.
  7. Must meet one of the two categories:
    1. Presenting Problem(s) – One self-limited or minor problem 
    2. Management Options Selected
      1. Observation
      2. Home care instructions, i.e. warm compresses, lid scrubs

Established Patient 99212 – what you need to document

Usually the presenting problems are of low severity. The same rules as above apply here as well.

THIS NEEDS ALL 3 COMPONENTS – 

  • An expanded problem focused history
  • An expanded problem focused examination
  • Straightforward medical decision making

Established Patient 99213 – what you need to document

Usually the presenting problem(s) are of low to moderate severity

For 99212 and 99213, you HAVE to have 2 out of these 3 components 

  • Problem focused history
  • A problem focused examination
  • Medical decision making (This has to be present)

Providers need to document for ESTABLISHED patients

  1. The same points 1-7 as above 
  2. For point 7, 99213 criteria is different
    1. Presenting Problem(s)
      • Two or more self-limited or minor problems
      • One stable chronic illness
      • Acute uncomplicated illness or injury
    2. Management Options Selected
      1. Over-the-counter drugs or RX
      2. Minor surgery recommended with no identified risk factors

Visit timings (how long should they be)

So how long should the visits be? Follow this list below to understand what to code. Do keep in mind that all the time a physician spends during the telemedicine call, charting, reviewing patient data .. ALL of it counts.

  • 99201: 10 minutes
  • 99202: 20 minutes
  • 99203: 30 minutes
  • 99204: 45 minutes
  • 99205: 60 minutes
  • 99212: 10 minutes
  • 99213: 15 minutes
  • 99214: 25 minutes
  • 99215: 40 minutes

Points to note for billing

  1. Code level selection is based on the same criteria for the base codes.
  2. Appending modifier -95 is optional during the public emergency.
  3. List place of service as 11 (same as an office location)

How to decide what’s billable and what’s not?

Just follow this decision tree.

  1. If it was a video call – you can bill right away as a telehealth visit (based on the guides above)
  2. If it was a phone call, find out if the patient’s insurance covers phone calls or not. If they cover it, you can bill right away (based on the guides above). If they do not cover it, next step is to find out if the telephone encounter was related to an E/M 7 days prior or resulted in an E/M encounter within 24 hrs after this call. If it did, then it is an un-billable visit. However, if it did NOT, then you need to ask whether this encounter included assessment and management of patient problem? If so – go ahead and bill this as a Telephone only E/M.
  3. For secure chat or secure email consults, first ask whether the patient initiated it or not. If the patient did not initiate it, then you cannot bill for it. But if the patient did initiate the consult via secure email/secure chat, you need to ask if this was related to an E/M 7 days prior. If it is, then you cannot bill for it. However, if it was not related to an E/M 7 days prior, ask yourself whether you are going to provide E/M service within the next 7 days or not. If not, then ask if you are going to provide E/M services in the next 24 hrs. If you are going to see the patient in the next 24 hrs AND you are going to include assessment and management of the patient problem, then you can go ahead and bill this as an eVisit.
  4. However, if you are going to provide services in the next 7 days, ask yourself whether the practice has seen this patient in the last 3 years or not (i.e. has this billing turned into a “new patient” visit or not). If the patient has not come in to see you in the past 3 years, then you cannot bill for it. However, if the patient has been seen in the last 3 years and you are going to provide services based on an image or a video that the patient sent, then go ahead and bill this as a “Virtual Checkin”.

What you need to do for virtual checkins (HCPCS code G2012) documentation requirements

  1. Confirm patient identity (e.g., name, date of birth or other identifying information as needed, in particular if documenting independently from the patient’s electronic or paper record).
  2. Detail what occurred during the communication (e.g., patient problem(s), details of the encounter as warranted) to establish medical necessity.
  3. Document the total amount of time spent in communicating with the patient and only submit code G2012 if a minimum of five minutes of direct communication with the patient was achieved.
  4. Document that the nature of the call was not tied to a face-to-face office visit or procedure that occurred within the past seven days.
  5. Document that a subsequent office visit for the patient’s problems were not indicated within 24 hours or the next available appointment.
  6. Include that the patient provided consent for the service

These should get you started. Overall, if you pick a telemedicine technology platform that already includes billing assistance, that’s of great help.

Telemedicine is here to stay and our prediction is that it will be integrated into every willing practice’s clinical workflow to increase patient access to quality care. Let’s get into marketing telehealth services next.


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