This issue of Review, focused on trends and controversies, is one of my favorites because it affords me the opportunity to address timely issues within the profession. One of the most significant headline items in health care this year has been COVID-19 and the rapid growth of telehealth it has caused. Now, seven months into the pandemic with most practices offering telehealth services in one way or another, is a good time to examine its impact.
Telehealth, available since 2017, refers to a distinct level of services that have traditionally been performed via a virtual face-to-face interaction, with audio and/or video connections, between the patient and physician.
Prior to the COVID-19 Public Health Emergency (PHE), both the popularity and use of telehealth was minimal due to several constraints. The service platform came with significant restrictive rules on its use, as well as low reimbursements. Perhaps the most significant for us, it’s not conducive to a hands-on, close-quarters profession such as optometry. It is difficult to see a staining pattern or examine the retina via telehealth. I’m not saying that it can’t be done, but it’s difficult to say the least.
In response to the PHE in March, the CMS relaxed the rules that surround how and where a clinician can provide telehealth services:
- Medicare can pay for office, hospital and other visits furnished via telehealth across the country, including the patient’s place of residence. In essence, this allows telehealth services to be provided without the previous geographic or location-based restrictions.
- The Office of Inspector General is allowing health care providers to reduce or waive cost-sharing for telehealth visits paid by federal health care programs. Of course, patients must be notified that a claim will be submitted to the payer.
- The requirement to store communication and ensure HIPAA compliance for all patient communications is not being enforced during the PHE, which allows for telehealth services to be provided using “everyday communications technologies” such as FaceTime or Zoom.
- Services can now be provided to both new and established patients.
- Telephone services are now reimbursed.
- Place of service rules were modified to all POS 11 (office) to be used for telehealth services rather than the POS 2 (telehealth) indicator.
- CMS added the eye visit codes to the list of covered exams during the COVID-19 PHE. Documentation requirements, however, remain the same: 92002 and 92012 are achievable via virtual face-to-face interaction; place of service is 11 and append modifier -95.
Note that this expansion of coverage may be unique to CMS.
These relaxed rules were given a 90-day extension on July 25, 2020. So, they will be in place until the end of this month, at least.
Once this PHE has subsided, I suspect some of these relaxations will stay in place and others will revert to their prior status. For example, the prior requirement that a patient must live in a physician shortage area and must travel to a properly qualified facility to initiate a telehealth service will likely never be reinstated. I believe that the patient will be able to live anywhere and will be able to initiate the telehealth service from anywhere, including their home.
However, I don’t see the use of common platforms such as Zoom or FaceTime continuing, and the return to the specific use of a HIPAA-protected portal is inevitable. Additionally, the ability to waive copays and deductibles most likely won’t continue, as carriers will resume passing that cost on to the consumer of care.
How and when things go back to normal is yet to be seen, but we can now all speak from experience when it comes to telehealth and can better evaluate its place in our practice going forward. So, friend or foe?
Send your coding questions to firstname.lastname@example.org.
|1. US Department of Health and Human Services. Renewal of determination that a public health emergency exists. www.phe.gov/emergency/news/healthactions/phe/Pages/covid19-23June2020.aspx. July 23, 2020. Accessed September 3, 2020.|
Summary of Codes Currently Covered
|CPT Code||Time||Modifier Used||POS|
|Evaluation & Management Visits|
|Evaluation of Static or Video Images|
|Online Digital Evaluations|
|99423||21 min or more||NA||11|
|Physician and Patient Phone Calls|
|99443||21 or more min||NA||11|
|99446||5-10 min||NA||11 or 22|
|99447||11-20 min||NA||11 or 22|
|99448||21-30 min||NA||11 or 22|
|99449||31 min or more||NA||11 or 22|
|99451||5 min or more||NA||11 or 22|
|99452||30 min||NA||11 or 22|