• Telemed definitions (time intervals above)
- CPT codes 99441: Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment.
99442 Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the txt 24 hours or soonest available appointment; 11-20 minutes of medical discussion
99443 21-30 minutes of medical discussion
Telephone Services
Codes 99441-99443 are non-face-to-face E/M services provided to a patient using the telephone by a physician or other QHP who may report E/M services. These codes are used to report episodes of patient care initiated by an established patient or guardian of an established patient. If the telephone service ends with a decision to see the patient within 24 hours or next available urgent visit appointment, the code is not reported; rather the encounter is considered part of the preservice work of the subsequent E/M service, procedure, and visit. Likewise, if the telephone call refers to an E/M service performed and reported by that individual within the previous 7 days (either requested or unsolicited patient follow-up) or within the postoperative period of the previously completed procedure, then the service(s) is considered part of that previous E/M service or procedure. (Do not report 99441-99443, if 99421, 99422, or 99423 have been reported by the same provider in the previous 7 days for the same problem.)
Interprofessional Telephone/Internet/Electronic Health Record Consultations (99446-99449, 99451, 99452) are assessment and management services in which a patient’s treating (e.g., attending or primary) physician or other QHP requests the opinion and/or treatment advice of a physician with specific specialty expertise (the consultant) to assist the treating physician or other QHP in the diagnosis and/or management of the patient’s problem without patient face-to-face contact with the consultant. The patient for whom the interprofessional telephone/Internet/electronic health record consultation is requested may be either a new patient to the consultant or an established patient with a new problem or an exacerbation of an existing problem. However, the consultant should not have seen the patient in a face-to-face encounter within the last 14 days. When the telephone/Internet/electronic health record consultation leads to a transfer of care or other face-to-face service
(e.g., a surgery, a hospital visit, or a scheduled office evaluation of the patient) within the next 14 days or next available appointment date of the consultant, these codes are not reported.
Review of pertinent medical records, laboratory studies, imaging studies, medication profile, pathology specimens, etc. is included in the telephone/Internet/electronic health record consultation service and shouldnot be reported separately when reporting 99446, 99447, 99448, 99449, 99451. The majority of the service time reported (greater than 50%) must be devoted to the medical consultative verbal or Internet discussion. If greater than 50% of the time for the service is devoted to data review and/or analysis, 99446, 99447, 99448, 99449 should not be reported. However, the service time for 99451 is based on total review and interprofessional-communication time. If more than one telephone/Internet/electronic health record contact(s) is required to complete the consultation request (e.g., discussion of test results), the entirety of the service and the cumulative discussion and information review time should be reported with a single code. Codes 99446, 99447, 99448, 99449, 99451 should not be reported more than once within a seven-day interval. The written or verbal request for telephone/Internet/electronic health record advice by the treating/requesting physician or other QHP should be documented in the patient’s medical record, including the reason for the request. Codes 99446, 99447, 99448, 99449 conclude with a verbal opinion report and written report from the consultant to the treating/requesting physician or other QHP. Code 99451 concludes with only a written report.
Telephone/Internet/electronic health record consultations of less than five minutes should not be reported. Consultant communications with the patient and/or family may be reported using 98966, 98967, 98968, 99421, 99422, 99423, 99441, 99442, 99443 and the time related to these services is not used in reporting 99446-99449.
Do not report 99358, 99359 for any time within the service period, if reporting 99446, 99447, 99448, 99449, 99451. When the sole purpose of the telephone/Internet/electronic health record communication is to arrange a transfer of care or other face-to-face service, these codes are not reported. The treating/requesting physician or other QHP may report 99452 if spending 16-30 minutes in a service day preparing for the referral and/or communicating with the consultant. Do not report 99452 more than once in a 14-day period. The treating/requesting physician or other QHP may report the prolonged service codes 99354-99357 for the time spent on the interprofessional telephone/Internet/electronic health record discussion with the consultant (e.g., specialist) if the time exceeds 30 minutes beyond the typical time of the appropriate E/M service performed and the patient is present (on-site) and accessible to the treating/requesting physician or other QHP. If the interprofessional telephone/Internet/electronic health record assessment and management service occurs when the patient is not present and the time spent in a day exceeds 30 minutes, then the non-face-to-face prolonged service codes 99358, 99359 may be reported by the treating/requesting physician or other QHP.
Coding tip The CPT half-way point regarding time (according to CPT Professional Edition 2020): “A unit of time is attained when the mid-point is passed. For example, a half hour is attained when 16 minutes have elapsed (more than midway between zero and 30 minutes).”
Brief Communication Technology-based Service, e.g. Virtual Check-in (HCPCS code GVCI1)
CMS is proposing to create a new G-code to pay for brief communication technology-based services. GVCI1 (Brief communication technology based service, e.g. virtual check-in, by a physician or other qualified health professional who may report evaluation and management services provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion)
The descriptor and valuation were based on CPT code 99441 for telephone evaluation and management services. CMS is proposing a work RVU of 0.25 based on a direct crosswalk to 99441. The national average payment rate for the physician office-based service is $15.14 and for the hospital outpatient based physician service it is $13.34.
Physician Telephone Services:
99441: Telephone evaluation and management service provided by a physician to an established patient, parent, or guardian not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion (.38 RVU)
CPT Codes 99441 – 99443; 98966 – 98968
• NOTE: The California Business and Professions Code prohibits prescribing dispensing, or furnishing dangerous drugs (drugs or devices that require Rx) without an appropriate prior examination and medical indication unless one of the following exceptions described below applies:
(1) The licensee was a designated physician and surgeon or podiatrist serving in the absence of the patient’s physician and surgeon or podiatrist and if the drugs were prescribed, dispensed or furnished only as necessary to maintain the patient until the return of his or her practitioner, but in any case no longer than 72 hours.
(2) The licensee transmitted the order for the drugs to a registered nurse or a licensed vocational nurse in an inpatient facility, and if both of the following conditions are met:
(A) The practitioner had consulted with the RN or LVN who had reviewed the patient’s records.
(B) The practitioner was designated as the practitioner to serve in the absence of the patient’s physician or surgeon or podiatrist, as the case may be.
(3) The licensee was a designated practitioner serving in the absence of the patient’s physician and surgeon or podiatrist, as the case may be, and was in possession of the patient’s records and ordered the renewal of a medically indicated prescription for an amount not to exceed the original prescription in strength or amount or more than one refill.
(4) The licensee was acting in accordance with Section 120582 of the Health and Safety Code. (For a diagnosis of a sexually transmitted Chlamydia, gonorrhea or other sexually transmitted infection, a provider may provide prescription antibiotic drugs to a patient’s partner without examination.
HCPCS Code Descriptions
G2012- Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5–10 minutes of medical discussion.
G2252- Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 11- 20 minutes of medical discussion.
HCPCS codes G2012 and G2252 may be reported to Medicare only unless otherwise directed by a private payer. Brief communication check in services may be reported to private payers with CPT® codes 99441 or 99442 (telephone evaluation and management services). Check payer policies for guidance on appropriate reporting.
Guidelines and Reporting
CPT® code 99439 would be reported with CPT® code 99490 (chronic care management service, first 20 minutes of clinical staff), no more than twice per calendar month.
The following CPT® codes may not be reported with 99439 in the same calendar month: 90951-90970, 99339, 99340, 99374, 99375, 99377, 99378, 99379, 99380, 99487, 99489, 99491, 99605, 99606, 99607.
In addition, if service time has been reported with CPT® codes 93792, 93793, 98960, 98961, 98962, 98966, 98967,98968, 98970, 98971, 98972, 99071, 99078, 99080, 99091, 99358, 99359, 99366, 99367, 99368, 99421, 99422, 99423, 99441, 99442, 99443, 99605, 99606, 99607 the work may NOT be counted towards the time of 99439 or 99490. For example, if the physician or QHP already provided an Online Digital E/M service for the patient (CPT® code 99421), that time may not be included in the time for the chronic care management service.
CPT® has also updated the list of codes that should not be reported in the same calendar month and for service time for CPT code 99491 (Chronic care management service provided by a physician or qualified healthcare professional).
Q. We are using our digital online portal to communicate with patients. When the physician starts a communication with a patient about an issue (such as an ongoing chronic issue) and it meets the requirements for reporting a digital online E/M service (eg, 99442) what are the constraints? Meaning if we end up seeing the patient, can we report both the online and the office-based E/M services?
A. It depends. The digital online E/M service is a “7-day cumulative service.” Determine the day the digital online E/M service begins, which is the date of the initial communication from the patient. Let’s say the initial communication begins on March 10 and there is digital online communication through March 13, when the condition is “resolved.” If you end up seeing the patient in your office for a related condition after March 13, but on or before March 17 (ie, 7 days after the initial date of service of March 10), you cannot separately report the digital online E/M service. It would all be “bundled” into the office visit code (even if provided via telemedicine).
If, however, the patient experiences a flare up on March 22 and you see her, you may report both the digital online E/M service (making sure dates of service line up with when the service took place) and the office visit (eg, 99213) – even if provided via telemedicine.
Qualifying Patients:
These services can be furnished to both new and established patients, even though the codes are intended for established patients only and their code descriptors reflect this. During the public health emergency, CMS is exercising enforcement discretion to relax enforcement of this aspect of the code descriptors.
Qualifying Practitioners:
• CPT codes 99441-99443 describe telephone evaluation and management services by a physician or other qualified healthcare professional who may report E/M services.
• CPT codes 98966-98968 describe telephone assessment and management services by a practitioner who cannot separately bill for E/M services. CMS elaborates that this means the codes “may be furnished by, among others, LCSWs, clinical psychologists, and physical therapists, occupational therapists, and speech language pathologists when the visit pertains to a service that falls within the benefit category of those practitioners.”
• These are time-based codes that describe 5-10 minutes of medical discussion (99441/98966); 11-20 minutes of medical discussion (99442/98967); 21-30 minutes of medical discussion (99443/98968).
How are 99441–99443 (telephone E/M service) codes different from 99211– 99215 codes?
99441–99443 are specific to a telephone encounter with an established patient and are not a result of an E/M provided within the previous seven days, OR within the next 24 hours. 99211–99215 are reported for a full E/M encounter with the same documentation requirements as an in-person service.
Is G2012 specific for Medicare and 99441–99443 for Medicaid?
No. Commercial payers also cover G2012. In the past Medicaid was the only payer that covered the telephone CPT codes 99441–99443. However, as of March 30, 2020,
CMS will cover telephone E/M codes 99441–99443 for the duration of the emergency declaration.
If you perform a telehealth E/M and decide that the patient must come into the office, can you bill for both the telehealth visit and the office visit if performed on different days?
No, the telephone E/M consultation codes (99441–99443) cannot be reported if the call leads to an E/M service or procedure within the next 24 hours or soonest available appointment.
Q. Can we can report “telemedicine” using audio only – like a telephone call?
A. It can vary by payer. However, CPT and is making allowances during this COVID-19 outbreak to allow telemedicine services to no longer require the “video” portion if it is not available — yet still report the service as a telemedicine service with modifier 95. Please refer to the AMA CPT Coding Guidance for more details.
Additionally, while CMS requires that audio-only visits be reported with the Telephone Care codes (99441-99443), Medicare payment for those codes has been made equivalent to the Office Visit codes (99201-99215). In addition, the HHS Office for Civil Rights (OCR) is exercising enforcement discretion and waiving penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the PHE.
As always, please check with your payers before implementing any new coding guidance — and make sure to get any policy declarations in writing.
Q. CMS requires that audio-only encounters (ie, telephone calls) be reported with Telephone Care codes (99441-99443), even though Medicare physicians will be paid commensurate with Office Visit telemedicine services. What are the documentation requirements for providing such a service?
A. While CMS does not offer documentation guidance for these services, the AAP offers the following guidance for patient safety, care continuity, and medical liability purposes: document audio-only encounters thoroughly as one would document an encounter provided via a real-time (synchronous) interactive audio + video elecommunications system
Q. Which date of service should I report for Telephone Care (99441-99443) and eVisits (99421-99423)?
A. The date of service will vary depending on the service that you provide. For Telephone Care, the date of service is the date you speak to the patient/parent. The clock will then “re-set” the next calendar day. Therefore, if you speak with the family again the next day (eg, dad calls to clarify something), you will report another Telephone Care service based on time spent. However, remember that no Telephone Care service is separately reportable 7 days prior to or within 24
hours/soonest available appointment from a related E/M service.
Medicare Telehealth Visits:
Effective for services starting March 6, 2020, and for the duration of the COVID-19 Public Health Emergency (PHE), Medicare will make payments for Medicare telehealth services furnished to patients in broadened circumstances. During the PHE, clinicians can use popular applications that allow for video chat such as Apple FaceTime and Skype, thanks in part to enforcement discretion by the HHS Office of Civil Rights. Clinicians who seek additional privacy protections for telehealth while using video communication products should provide such services through technology vendors that offer HIPAA business associate agreements (BAAs) with their video communication products. In addition, clinicians may utilize telephone without video for other communication technology-based services.
• Patients may be either a new or established patient.
• These visits are the same services as would be provided during in-person visit and are paid at the same rate as in-person visits.
• The patient may be located in any geographic location (not just those designated as rural), in any healthcare facility, or in their home.
• The Medicare coinsurance and deductible would generally apply to these services; however, the HHS Office of the Inspector General is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.
- Common telehealth CPT and HCPCS codes include:
- 99201-99215: Office or other outpatient visits
- 0425-G0427: Telehealth consultations, emergency department or initial inpatient
- G0406-G0408: Follow up inpatient telehealth consultations furnished to beneficiaries in hospitals or skilled nursing facility (SNF)
Please note: In a case where two-way audio and video technology required to furnish a Medicare telehealth service might not be available, there are circumstances where prolonged, audio-only communication between the practitioner and the patient could be clinically appropriate yet not fully replace a face-to-face visit.
For the duration of the PHE for the COVID-19 pandemic, Medicare will make separate payment for audio-only visits described by CPT codes 98966-98968 and CPT codes 99441-99443 as outlined on page 125 in the Interim Final Rule with Comment.
