Yes.

When billing professional claims for all telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE), bill with:

• Place of Service (POS) equal to what it would have been had the service been furnished in-person
• Modifier 95, indicating the service rendered was actually performed via telehealth
• Alaska and Hawaii use asynchronous (Store and Forward) technology, use GQ modifier
• Furnished for diagnosis and treatment of an acute stroke, use GO modifier

There are no billing changes for institutional claims. Critical access hospital method II claims should continue to bill with modifier GT.

Medicare modifiers are:

• 95 – Synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system
  • Use of the 95 modifier indicates a real-time interaction between a physician or other qualified health care professional and a patient who is located at another site than his/her physician or other qualified health care professional or by him/herself.
  • Modifier 95 may be appended to the services listed in Appendix P of the CPT Code Book or marked with a star in the code lists within the CPT Code Book.
• GQ – Via asynchronous telecommunications system (e.g., 99201-GQ)
  • Use of the GQ modifier certifies an asynchronous telecommunications system was used, such as Store and Forward technologies, to transmit medical or behavioral health information to the provider at the “distant site.”
• GT – Via interactive audio and video telecommunication systems (e.g., 99201-GT)
  • Use of the GT modifier certifies the member was present at an eligible “originating site” when the telehealth/telemedicine service was performed.
  • This modifier is used exclusively by the “distant site” provider.
• G0 – Telehealth services for diagnosis, evaluation or treatment of symptoms of an acute stroke
  • This modifier should be appended to both the originating and distant site provider services as clinically appropriate when billing for an acute stroke telehealth service.
  • This modifier should be appended on services that were rendered or furnished in such sites as a hospital, critical access hospital or mobile stroke unit.
  • Such services should also be billed with the appropriate POS code on professional claims to indicate telehealth service.

All evaluation and management code (E&M) provider types and non-E&M providers can complete:
• Regular office visits
• E-visit: Must be initiated by the patient, usually through a patient portal; time based across a seven-day period
• Virtual check-in: Can be via phone, text, images to discuss assessment and treatment; time-based code but can not occur as a follow-up from an E&M visit or result in one
• Phone visits

The e-visits, virtual check-ins and phone visits are paid at pretty low rates. There is not yet clear guidance from the Centers for Medicare & Medicaid Services (CMS) about which modifiers should be used for non-E&M provider billing.

An example of an allied health provider completing telehealth:
A person with Medicare calls his physical therapist to cancel an upcoming appointment due to the need to shelter in place. The therapist informs the patient he can stay in contact with the therapist and continue receiving instruction and guidance on his home exercises and other home care elements by initiating an e-visit. The patient agrees. The therapist documents the patient’s initiation of the service and his consent to receive it. The therapist sets up the patient with access to a secure patient portal that allows him to send and receive messages and other materials such as exercise videos and images. The patient uses the portal to tell the therapist he is having trouble replicating some of the exercises at home due to lack of equipment. The therapist makes suggestions on how he can adapt the exercises using household items and sends recorded videos to demonstrate those suggestions. The therapist spends 30 minutes thinking about how to adapt the exercises, preparing the materials and sending them to the patient. The therapist does not provide any other services over the course of the seven-day period, so she bills one unit of G2063.

In general, all provider types that can bill an evaluation and management code (E&M) can now bill those services by telehealth, as long as it is clinically appropriate and there is real-time audio and visual contact with the patient. For specific codes, verify the service can be completed via telehealth by accessing https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.

All E&M provider types and non-E&M providers can complete:

• Regular office visits
• E-visits: Must be initiated by the patient, usually through a patient portal; time based across a seven-day period
• Virtual check-ins: Can be via phone, text or images to discuss assessment and treatment; time-based code but can not occur as a follow-up from an E&M visit or result in one
• Phone visits

The e-visits, virtual check-ins and phone visits are paid at pretty low rates. There is not yet clear guidance from the Centers for Medicare & Medicaid Services (CMS) about which modifiers to use for non-E&M provider billing.

N0 – However, you should see your state’s practice laws.

Yes, but more research is needed.

Billing requirements include:

• A consult requires a request from another health care professional for a new or established problem for your evaluation, assessment or opinion.
• After service is provided, a report is returned to the requesting clinician.
• Document the request in the medical record.
• Transfer of care is not a consult.
• Office consults are not defined as new or established.

No. The Centers for Medicare & Medicaid Services (CMS) has created blanket waivers for all Medicare billing. Consent of the patient should still be obtained for the visit and treatment. There has also been relief for providers to serve patients across state lines. However, state practice laws still apply, and you need to check those prior to rendering services.

An expanded list of services is available: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes

Over 80 visit types have been added. Providers can conduct telehealth visits in the inpatient, outpatient, long-term care, home health and hospice settings. If you are looking for a specific code, check the link above and search whether it is covered under the expansion.

Telehealth encounters can originate from any clinic, including a Federally Qualified Health Center (FQHC), a Rural Health Clinics (RHC) and a provider’s home. Reimbursement for originating site fees only apply if the patient comes to the clinic and the patient is connected to a distant site provider (like it used to be).

The Medicare waiver allows patients to be in their homes and for providers to connect with them from the provider’s office or phone.

Reference these Centers for Medicare & Medicaid Services (CMS) links:

Current Emergencies webpage: Has all COVID-19 memos, FAQs and fact sheets – https://www.cms.gov/About-CMS/Agency-Information/Emergency/EPRO/Current-Emergencies/Current-Emergencies-page

FAQ sheet: A list of FAQs regarding billing COVID-19-related services, including testing, treatment and telehealth: https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf

Health care provider fact sheet: Best overall resource for billing/code information: https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet