CA: Telehealth Video-Only Restrictions Changed; Audio-Only Allowed - Part 3

CA: Telehealth Video-Only Restrictions Changed; Audio-Only Allowed - Part 3

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:

  • Part 1 addressed the retroactive update to the Place of Service Code that is reported on the CMS 1500 when a provider furnishes telehealth services.
  • Part 2 analyzed the increased reimbursement for telephone CPT codes 99441 – 99443.
  • Today we address the adoption of the CMS updated Covered Telehealth Services, including newly added audio telehealth services.

Medicare Eliminates Video Requirements for Selected Telehealth Services

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.

California DWC Adopts Audio-Only Telehealth Services

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, sign up for our next free webinar. Major reimbursement increases and expansion of audio-only services are just the beginning. 

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