What We Know Today 4-15-20

I’ve held off writing for a while as a result of so many policy changes occurring so quickly in the storm of this pandemic. Within the first weeks, information I had written and one of the podcasts we produced contained conflicting instructions because telehealth coding was changing before I could place the final period on a communication. But a little time has passed, and the initial flurry is beginning to settle down. And the best part is many are reporting payments for Telehealth services, and we are seeing payments with my clients as well.

On April 6th, 2020 HHS published the final rule in the Federal Register pertaining to Telehealth visits, proper code elements, and scope of use. Below are few highlights from my good friend Tamra Lahmer of Mediquick Physician Services. Her full summary will be available on our website IMSTX.net.


  1. Continue to use modifier -95 for services furnished via telehealth.
  1. Use the POS for the location that “would have” been reported if the service was furnished in person. This will pay the “non-facility” rate which is higher than the “facility” rate. If POS 02 is used, the facility rate will be paid.

E&M BASED ON MDM AND TIME (pgs 140-142)

  1. Office/outpatient E&M services furnished via telehealth may base the billed level of service on Medical Decision Making (MDM) or time. This ruling was already approved to go into effect on January 1, 2021 but is temporarily offered during the PHE period and for telehealth only.
  1. Time is defined as all of the time associated with the E&M on the day of the encounter. This includes face-to-face with the patient using technology and time outside of the patient encounter performing related services.
  1. Requirements for the history and/or physical exam have been removed for the telehealth E&M services.
  1. Definition of MDM will remain the same.
  1. Restated that the “policy only applies to office/outpatient visits furnished via Medicare telehealth, and only during the PHE for the COVID-19 pandemic.”

As you can see CMS made it very straightforward and removed much of the complication. Most of the confusion I’ve seen with billers and office managers is that they are overthinking it.

The other good news, and I’ll say I was wrong in my prediction, is most of the big commercial carriers are employing the same rule sets. If you remember several weeks ago, those carriers all had different code element requirements and it was nearly impossible to keep track of the modifier/POS combinations. So, take a deep breath and know that we’ve moved past a monumental period in this crisis.

What happens next? Well, all these changes could vanish overnight once the public health emergency is lifted. We could be back in a state of confusion with multiple combinations of payor policies. But I’m not so sure that’s exactly what will happen. Telehealth is on the scene in a big way. Many patients are stating they will continue expecting it after the Stay Home restrictions are lifted. I don’t have a feeling on future reimbursements, but I do believe the coding alignment between Medicare’s rules and commercial payors will be much clearer than what we had months ago. I don’t see a complete reversal occurring once this crisis has passed. And there is an argument for Medicare to maintain the Office Visit reimbursement levels for Telehealth simply as a safeguard for that population.

Again, Telehealth confusion is subsiding. Proper coding for Telehealth visits has normalized. Payments are being received for services rendered. And the footprint for Telehealth in society has just grown 100-fold.

Until next time.

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