April 9, 2020

During the COVID-19 Public Health Emergency, there are four non-face-to-face service types podiatrists can provide to most patients. A provider’s ability to employ these services may differ based on the patient’s insurance and state licensure. Some private insurers have issued guidelines that vary from what is listed below. Always check with payer and state licensure guidelines before providing any service.

For all of the services described below, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health-care providers who serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 emergency.

The four service options include:

As of March 30, 2020 CMS is allowing all four of these services to be provided for both new and established patients.

1. Telehealth for Medicare Part B and Medicare Advantage Patients—Services that are normally furnished in person which are instead furnished remotely using interactive, real-time telecommunication technology

On March 17, CMS announced that providers can perform certain E/M services when performed remotely. The provider can be in any location and the patient can be in any location. More services were added to that list and further clarification was provided on March 30, 2020.

Some private payers have followed suit, also allowing certain E/M services to be provided remotely. Check private payer policies for details.

For Medicare patients, providers can use this option for office/other outpatient E/Ms (CPT 99201–99215) and all services listed here

Must use a communication tool that has interactive audio and video

Communication tool must allow real-time communication

Providers are permitted to reduce or waive cost-sharing for these services if they wish

Use modifier 95

Use the Place of Service that would have been used had the service been rendered in person (e.g., POS 11 for CPT 99213 and POS 32 for CPT 99307)

These services will be paid at the regular rate

This waiver is in place as long as the public health emergency lasts

Postoperative global periods apply

Document a progress note just like one would do when this service is provided face-to-face. This interaction is an E/M service and the same documentation requirements apply. The level is selected based on the 1995 or 1997 CMS guidelines for evaluation and management services, except when using CPT 99202-99215. When using CPT 99202–99215 for telehealth, the level may be selected based on “Medical Decision Making alone or total time alone."

2. Use G2012 when a virtual check-in is provided to a Medicare Part B or Medicare Advantage patient using telephone interactions in addition to synchronous, two-way audio interactions that are enhanced with video or other kinds of data transmission

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 seven 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

Can be any type of telecommunication tool, including telephone

CANNOT relate to any service in the last seven days

CANNOT result in patient coming in within the next 24 hours or soonest available appointment

No modifiers needed

Providers are permitted to reduce or waive patient cost-sharing for these services if they wish

3. Telephone E/M services for patients with any insurance



This interaction is an E/M service and documentation must support an E/M just like any other E/M type. Must have history, as much of an evaluation as possible, and some form of medical management.

Must be initiated by patient or the patient’s guardian

Provider may educate patients about this option

Not reimbursed by some payers

CANNOT report if call results in decision to see patient within 24 hours or next available urgent appointment

CANNOT report if call refers to E/M service performed by same provider within previous seven days

CANNOT report if call refers to a problem for which a patient is in a global period

CANNOT report if provider performed a telephone E/M or online digital E/M for the same patient for the same problem in the last seven days

CANNOT report if the call is part of Home Care Oversight Services, Care Plan Oversight Services, Home/Outpatient INR Monitoring, Complex Care Management Services, or Transitional Care Management Services CPT 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 seven 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 CPT 99442– ; 11–20 minutes of medical discussion CPT 99443– ; 21–30 minutes of medical discussion



4. Online digital E/M services for patients with any insurance



This interaction is an E/M service and documentation must support an E/M just like any other E/M type. Must have history, as much of an evaluation as possible, and some form of medical management.

Examples of digital platforms: Electronic health record Email Text message Other two-way digital communication

Must be initiated by patient via a digital platform

Provider may educate patients about this option

Not reimbursed by some payers

Providers are permitted to reduce or waive patient cost-sharing for these services if they wish

CANNOT report if service refers to a problem for which a patient is in a global period

CANNOT report if service is initiated within seven days of any E/M for same problem

CANNOT report if performed on same day as in-person E/M service

CANNOT report if service is part of Home Care Oversight Services, Care Plan Oversight Services, Home/Outpatient INR Monitoring, Complex Care Management Services, or Transitional Care Management Services

Time spent is cumulative time over seven days starting with review of the request

Can only report once per seven-day period

Time includes: Review of inquiry Review of patient records Interaction with other staff Development of management plan Rx Ordering tests Communication with patient

Add time if multiple providers in same practice perform this service for the same patient over the same seven-day period

If within seven days of the initiation of an online digital E/M service, a separately reported E/M visit occurs, then the provider work devoted to the online digital E/M service is incorporated into the separately reported E/M visit

days of the initiation of an online digital E/M service, a separately reported E/M visit occurs, then the provider work devoted to the online digital E/M service is incorporated into the separately reported E/M visit CPT 99421: Online digital evaluation and management service, for an established patient, for up to seven days, cumulative time during the seven days; 5–10 minutes

CPT 99422 ; 11–20 minutes

CPT 99423 ; 21 or more minutes

APMA suggests obtaining informed consent for these services. APMA further suggests that members advise patients that there will be a charge for these services, that copays and deductibles may apply, and referrals may be necessary if required by the insurance plan.

5. Watch a video summarizing this information

6. Listen to a podcast about this information

We have recorded a special episode of The APMA Podcast about providing telemedicine services. Listen below.

References:

Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency http://hhs.com/assets/docs/covid-final-ifc.pdf

CMS Fact Sheet: https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet

Current Procedural Terminology (CPT®) is copyright 1966, 1970, 1973, 1977, 1981, 1983–2019 by the American Medical Association. All rights reserved. CPT is a registered trademark of the American Medical Association (AMA). Reference: 2020 CPT Professional

CPT codes and their descriptions do not reflect or guarantee coverage or payment. Just because a CPT code exists, payment for the service it describes is not guaranteed. Coverage and payment policies of governmental and private payers vary from time to time and for different areas of the country. Questions regarding coverage and payment by a payer should be directed to that payer. APMA and its employees, consultants, and officers do not claim responsibility for any consequences or liability attributable to the use of any information, guidance, or advice contained in this communication or liability attributable to the use of any information, guidance, or advice contained in this communication.

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