Medicare Releases REVISED Telehealth Rules - Part 2

Medicare Releases REVISED Telehealth Rules - Part 2

This is part two of our series analyzing telehealth reimbursement rule changes that were announced last week by the Centers for Medicare & Medicaid Services (aka “CMS'' or “Medicare”). Because many states take their cue from Medicare when establishing workers’ comp reimbursements, we’re closely following and reporting on these updates.

Today we will review the following additional changes to Medicare telehealth rules.

  • Reimbursement increase for audio-only telephone evaluation and management services
  • Audio-only allowed for designated telehealth services

See yesterday’s blog post for our write-up of the following Medicare telehealth changes:

  • Waiver of the types of practitioners allowed to furnish telehealth services
  • Medical services added to allowed telehealth service list

Audio-Only Telephone Evaluation and Management Reimbursements Increase

In the most recent Medicare and Medicaid IFC: Additional Policy and Regulatory Revisions (CMS-5531 IFC), Medicare acknowledged that audio-only medical services are more prevalent than anticipated. CMS further acknowledged that when many patients are unable to communicate using video technology, providers are forced to use audio-only communications (aka “telephones”) as the only alternative to an in-person or video telehealth visit.

“...stakeholders have informed us that use of audio-only services is more prevalent than we had previously considered, especially because many beneficiaries are not utilizing video-enabled communication technology from their homes. In other words, there are many cases where practitioners would under ordinary circumstances utilize telehealth or in-person visits to evaluate and manage patients’ medical concerns, but are instead using audio-only interactions to manage more complex care.”

Without the appropriate video technology or in-office visits, providers are furnishing patients evaluation and management services via audio-only (telephone) technology. In its latest revision to telehealth rules, the CMS recognized that reimbursements established for these telephone evaluations failed to adequately reimburse providers for the services actually being rendered during these telephone evaluations.

“...we are now recognizing that the intensity of furnishing an audio-only visit to a beneficiary during the unique circumstances of the COVID-19 pandemic is not accurately captured by the valuation of these services we established in the March 31st COVID-19 IFC.”

To adequately reimburse providers for the audio-only services, CMS is increasing payments for telephone evaluation and management visits to match payments for similar office and outpatient visits. Specifically, Medicare is crosswalking CPT codes 99212, 99213, and 99214 to 99441, 99442, and 99443 respectively. The increased reimbursement payments are retroactive to March 1, 2020.

“Given our new understanding that these audio-only services are being furnished primarily as a replacement for care that would otherwise be reported as an in-person or telehealth visit using the office/outpatient E/M codes, we are establishing new RVUs for the telephone E/M services based on crosswalks to the most analogous office/outpatient E/M codes, based on the time requirements for the telephone codes and the times assumed for valuation for purposes of the office/outpatient E/M codes.”

Audio-Only for Designated Telehealth Services

Prior to last week’s change, CMS required providers to furnish all telehealth services using interactive video telecommunications systems. To the extent a patient could not accommodate a video visit, the provider was expected to furnish an audio-only telephone evaluation and to report this audio encounter with time-based telephone codes CPT 99441 through CPT 99443.

For certain behavioral health counseling and educational services  telehealth services, CMS is waiving the requirements for use of interactive video telecommunications systems to furnish the telehealth service. This waiver allows the use of audio-only equipment to furnish services described by the codes.

Unless provided otherwise, other services included on the Medicare telehealth services list must be furnished using, at a minimum, audio and video equipment permitting two-way, real-time interactive communication between the patient and distant site physician or practitioner.

Below are the designated codes where audio-only is allowed to furnish the medical service. (see designated codes. The CMS will be periodically updating its  List of Telehealth Services.

Code

Short Descriptor

Status

Can Audio-only Interaction Meet Requirements?

90853

Group psychotherapy

Temporary Addition for the PHE for the COVID-19 Pandemic

Yes

92507

Speech/hearing therapy

Temporary Addition for the PHE for the COVID-19 Pandemic

Yes

92521

Evaluation of speech fluency

Temporary Addition for the PHE for the COVID-19 Pandemic

Yes

92522

Evaluate speech production

Temporary Addition for the PHE for the COVID-19 Pandemic

Yes

92523

Speech sound lang comprehen

Temporary Addition for the PHE for the COVID-19 Pandemic

Yes

92524

Behavral qualit analys voice

Temporary Addition for the PHE for the COVID-19 Pandemic

Yes

96130

Psycl tst eval phys/qhp 1st

Temporary Addition for the PHE for the COVID-19 Pandemic

Yes

96131

Psycl tst eval phys/qhp ea

Temporary Addition for the PHE for the COVID-19 Pandemic

Yes

96132

Nrpsyc tst eval phys/qhp 1st

Temporary Addition for the PHE for the COVID-19 Pandemic

Yes

96133

Nrpsyc tst eval phys/qhp ea

Temporary Addition for the PHE for the COVID-19 Pandemic

Yes

96136

Psycl/nrpsyc tst phy/qhp 1st

Temporary Addition for the PHE for the COVID-19 Pandemic

Yes

96137

Psycl/nrpsyc tst phy/qhp ea

Temporary Addition for the PHE for the COVID-19 Pandemic

Yes

96138

Psycl/nrpsyc tech 1st

Temporary Addition for the PHE for the COVID-19 Pandemic

Yes

96139

Psycl/nrpsyc tst tech ea

Temporary Addition for the PHE for the COVID-19 Pandemic

Yes

97535

Self care mngment training

Temporary Addition for the PHE for the COVID-19 Pandemic

Yes

92508

Speech/hearing therapy

Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20

Yes

96121

Nubhvl xm phy/qhp ea addl hr

Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20

Yes

96127

Brief emotional/behav assmt

Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20

Yes

96158

Hlth bhv ivntj indiv 1st 30

Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20

Yes

99441

Phone e/m phys/qhp 5-10 min

Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20

Yes

99442

Phone e/m phys/qhp 11-20 min

Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20

Yes

99443

Phone e/m phys/qhp 21-30 min

Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20

Yes

90785

Psytx complex interactive

Yes

90791

Psych diagnostic evaluation

Yes

90792

Psych diag eval w/med srvcs

Yes

90832

Psytx w pt 30 minutes

Yes

90833

Psytx w pt w e/m 30 min

Yes

90834

Psytx w pt 45 minutes

Yes

90836

Psytx w pt w e/m 45 min

Yes

90837

Psytx w pt 60 minutes

Yes

90838

Psytx w pt w e/m 60 min

Yes

90839

Psytx crisis initial 60 min

Yes

90840

Psytx crisis ea addl 30 min

Yes

90845

Psychoanalysis

Yes

90846

Family psytx w/o pt 50 min

Yes

90847

Family psytx w/pt 50 min

Yes

96116

Nubhvl xm phys/qhp 1st hr

Yes

96156

Hlth bhv assmt/reassessment

Yes

96159

Hlth bhv ivntj indiv ea addl

Yes

96160

Pt-focused hlth risk assmt

Yes

96161

Caregiver health risk assmt

Yes

96164

Hlth bhv ivntj grp 1st 30

Yes

96165

Hlth bhv ivntj grp ea addl

Yes

96167

Hlth bhv ivntj fam 1st 30

Yes

96168

Hlth bhv ivntj fam ea addl

Yes

96168

Hlth bhv ivntj fam ea addl

Yes

97802

Medical nutrition indiv in

Yes

97803

Med nutrition indiv subseq

Yes

97804

Medical nutrition group

Yes

99354

Prolong e&m/psyctx serv o/p

Yes

99355

Prolong e&m/psyctx serv o/p

Yes

99356

Prolonged service inpatient

Yes

99357

Prolonged service inpatient

Yes

99406

Behav chng smoking 3-10 min

Yes

99407

Behav chng smoking > 10 min

Yes

99497

Advncd care plan 30 min

Yes

99498

Advncd care plan addl 30 min

Yes

90785

Psytx complex interactive

Yes

G0108

Diab manage trn per indiv

Yes

G0109

Diab manage trn ind/group

Yes

G0270

Mnt subs tx for change dx

Yes

G0296

Visit to determ ldct elig

Yes

G0396

Alcohol/subs interv 15-30mn

Yes

G0397

Alcohol/subs interv >30 min

Yes

G0406

Inpt/tele follow up 15

Yes

G0407

Inpt/tele follow up 25

Yes

G0408

Inpt/tele follow up 35

Yes

G0420

Ed svc ckd ind per session

Yes

G0421

Ed svc ckd grp per session

Yes

G0425

Inpt/ed teleconsult30

Yes

G0426

Inpt/ed teleconsult50

Yes

G0427

Inpt/ed teleconsult70

Yes

G0436

Tobacco-use counsel 3-10 min

Yes

G0437

Tobacco-use counsel>10min

Yes

G0438

Ppps, initial visit

Yes

G0439

Ppps, subseq visit

Yes

G0442

Annual alcohol screen 15 min

Yes

G0443

Brief alcohol misuse counsel

Yes

G0444

Depression screen annual

Yes

G0445

High inten beh couns std 30m

Yes

G0446

Intens behave ther cardio dx

Yes

G0447

Behavior counsel obesity 15m

Yes

G0459

Telehealth inpt pharm mgmt

Yes

G0506

Comp asses care plan ccm svc

Yes

G0513

Prolong prev svcs, first 30m

Yes

G0514

Prolong prev svcs, addl 30m

Yes

G2086

Off base opioid tx 70min

Yes

G2087

Off base opioid tx, 60 m

Yes

G2088

Off base opioid tx, add30

Yes

Medicare Relevant Publication Links

As Medicare rapidly releases updates to telehealth rules and regulations, accessing the relevant documentation is imperative to understanding these updates. To trace the details imparted in the blog posts we have published and will publish over the next several days, the following is a complete list of the referenced documents:

  1. COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers - Updated 4/30/2020 
  2. List of Telehealth Services
  3. Medicare and Medicaid Coronavirus Waivers & Flexibilities
  4. Medicare and Medicaid IFC: Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency (CMS-5531 IFC) (PDF)
  5. Medicare IFC: Revisions in Response to the COVID-19 Public Health Emergency (CMS-1744-IFC) (PDF)
  6. Second Round of Sweeping Changes to Support U.S. Healthcare System During COVID-19 Pandemic


For more on telehealth rules for Medicare, California health insurers, and California workers’ compensation, look through the free resources available on our COVID-10 page.

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