As a result of the COVID-19 public health emergency, more and more physiatrists turned to telehealth as a key tool for caring for patients while maintaining social distancing. In light of the role of telehealth in the mitigation of COVID-19 exposure, the Centers for Medicare & Medicaid Services rolled out a series of waivers and policy updates which removed barriers to telehealth provision. These waivers and updates are currently expected to be in place into December 2022 and may be extended further. AAPM&R continues to advocate for permanent expansion of telehealth coverage.
This guide offers details on Medicare guidelines including a review of waivers, reimbursable codes, and CMS-recommended modifiers. Private payor policies with respect to telehealth during the public health emergency may vary. While many payors are looking to CMS for guidance in this space, we encourage members to contact their private payors and visit this AHIP resource for details on individual payor policies. This guide was last updated in March 2022. We anticipate additional updates will be warranted as the public health emergency ends.
Billing for Office Visits Provided by Telehealth
CMS historically has covered a range of services when provided via telehealth. A complete list of services reimbursable when performed by telehealth can be found on the Medicare website. This list includes notation regarding which services have been added under the public health emergency. Additional details can be found in the “Expansion of Covered Services” section of this guide.
During the COVID-19 public health emergency, many physiatrists are performing standard office visits via telehealth. These services should be billed using standard E/M codes. For example, a level 3 office visit provided to an established patient via telehealth should be billed using code 99213. See the “Modifiers and Place of Service” section of this guide for additional billing instructions.
Significant Waivers and Rule Changes
The Department of Health and Human Services (HHS) was granted authority to ease restrictions and expand coverage for telehealth. A comprehensive summary of waivers granted during the public health emergency, including telehealth waivers, can be found on the Medicare website.
- Providers can now see both new and established patients via telehealth.
- Patients can now receive telehealth visits from their home.
- Non-HIPAA compliant technology is allowed for telehealth services.
- Telehealth services are now paid at the same rate as standard office visits (this is achieved by billing using the place of service code that would have been used if the service was performed face-to-face; for example, POS 11 for office visit).
- Providers now have the ability to waive cost sharing (copays and deductibles) for all telehealth services.
- CMS has removed frequency limitations for certain services provided via telehealth:
- Telehealth frequency limitation of once every 30 days has been removed for subsequent inpatient visits (CPT codes 99321-99233)
- Telehealth frequency limitation of once every 30 days has been removed for subsequent nursing facility visits (CPT codes 99307-99310)
- Telehealth frequency limitation of once per day has been removed for critical care consult codes (Codes G0508-G0509)
- Telephone visits are covered (though currently at a rate far lower than standard telehealth visits).For more details on telephone visits, please see the “Billing for Telephone Calls” section of this guide.
Billing Guidance – Modifiers and Place of Service
CMS has directed providers to append modifier -95 to all telehealth services to indicate that the service is provided via telehealth. Modifier -95 replaced modifiers -GT and -GQ which CMS stopped using several years ago. Private payors may have different modifier requirements for telehealth services.
In 2022, CMS revised its policies regarding place of service codes for telehealth services. There are now two place of service codes which may be relevant to telehealth:
POS 02 - Telehealth provided other than in a patient’s home
POS 10 – Telehealth provided in a patient’s home
Our understanding is that several private payors, including Anthem and UnitedHealthcare, are also adopting these place of service definitions.
Expansion of Covered Services Provided Via Telehealth
- Under new authority, CMS expanded the list of services that can be reimbursed when provided via telehealth (including real-time audiovisual technology)
- Services can be provided to new or established patients
- Providers can waive Medicare copayments for these services when provided to beneficiaries in Original Medicare
- This list is in addition to the services Medicare already covers when provided via telehealth.Download the complete list of covered services on the Medicare website.
Additional guidance will be added regularly.
AAPM&R has also provided several webinars and demos related to telehealth that are available for free on the Online Learning Portal, including previously recorded webinars, slide lectures, and product demonstrations.