This is the third of our series on retroactive telehealth rule changes announced by the California Department of Workers’ Compensation (DWC) on 5/12/2020. Today we focus on the telehealth services which now allow audio-only as the method of interaction with the patient.
This is a three-part series of posts explaining the recent changes to allowed telehealth services and the reimbursement consequence of these rule changes.
This series covers the three major changes announced by the DWC:
On April 30, 2020, CMS added new services to its List of Telehealth Services that are eligible for reimbursement when furnished via telehealth. Even more importantly, Medicare acknowledged that audio-only medical services are more prevalent than anticipated. CMS further conceded 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.
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.
Following Medicare’s lead, the 5/7/2020 Administrative Director Order amends California Code of Regulations, section 9789.19, subdivision (g) to allow audio-only telehealth communications.
Prior to the 5/7/2020 change, the DWC 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.
This DWC change allows the use of audio-only equipment to furnish services described by the codes listed in the table below.
Unless provided otherwise, other services included on the Medicare telehealth services list must still 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.
To the extent an ill or injured worker cannot participate in video telehealth treatment, a provider is allowed to furnish audio-only evaluation. In Part 2 of this series, we discuss the reimbursement for these telephone 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 |
For a comprehensive look at recent changes to telehealth rules for both Medicare and CA workers’ comp, watch our free webinar. Major reimbursement increases and expansion of audio-only services are just the beginning.
DaisyBill provides content as an insightful service to its readers and clients. It does not offer legal advice and cannot guarantee the accuracy or suitability of its content for a particular purpose.