American Society of Plastic Surgeons
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COVID-19 Telemedicine Resources

The Centers for Medicare and Medicaid Services (CMS) recently announced changes to key telemedicine provisions to expand access for Medicare recipients during the COVID-19 pandemic to ensure that Medicare beneficiaries can access telemedicine services under the emergency authority granted to the Secretary. As part of this announcement, patients will now be able to access their doctors using a wider range of communication tools including telephones that have audio and video capabilities, making it easier for beneficiaries and doctors to connect.

CMS has developed new information regarding the implementation of this policy, including a press release, fact sheet and updated FAQ.

The key takeaways from the announcement are as follows:

  • Effective for services starting March 6, 2020, and for the duration of the COVID-19 Public Health Emergency, Medicare will make payment for Medicare telemedicine services furnished to patients in broader circumstances.
  • These visits are considered the same as in-person visits and are paid at the same rate as regular, in-person visits.
  • Starting March 6, 2020, and for the duration of the COVID-19 Public Health Emergency, Medicare will make payment for professional services furnished to beneficiaries in all areas of the country in all settings.
  • While they must generally travel to or be located in certain types of originating sites such as a physician's office, skilled nursing facility or hospital for the visit, effective for services starting March 6, 2020, and for the duration of the COVID-19 Public Health Emergency, Medicare will make payment for Medicare telemedicine services furnished to beneficiaries in any healthcare facility and in their home.

This guidance and other recent actions by CMS provide regulatory flexibility to ensure that all Medicare beneficiaries – particularly high-risk individuals – are aware of easy-to-use, accessible benefits that can help keep them healthy while helping to contain the spread of coronavirus disease 2019 (COVID-19).

Note that Medicare coinsurance and deductible would generally apply to these services. However, the HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telemedicine visits paid by federal healthcare programs so that cost won't be a barrier to care.

There are three main types of virtual services, as outlined in the following table.

Type of Service What Is the Service? HCPCS/CPT Code Patient Relationship with Provider

Medicare Telehealth Visits

A visit with a provider that uses telecommunication systems between a provider and a patient.

Common telehealth services include:

  • 99201-99215 (Office or other outpatient visits)
  • G0425-G0427 (Telehealth consultations, emergency department or initial inpatient)
  • G0406-G0408 (Follow-up inpatient telehealth consultations furnished to beneficiaries in hospital or SNFs)

Click here for a complete list.

For new* or established patients.

*To the extent the 1135 waiver requires an established relationship, HHS will not conduct audits that such as prior relationship existed for claims submitted during this public health emergency.

Virtual Check-In

A brief (5-10 minutes) check in with your practitioner via telephone or other telecommunications device to decide whether an office visit or other service is needed. A remote evaluation of recorded video and/or images submitted by an established patient.

  • HCPCS code G2012
  • HCPCS Code G2010

For established patients.

E-Visits

A communication between a patient and their provider through an online patient portal.

  • 99421
  • 99422
  • 99423
  • G2061
  • G2062
  • G2063

For established patients.

Medicare Telehealth Visits

What Is the Service?

A visit with a provider that uses telecommunication systems between a provider and a patient.

HCPCS/CPT Code

Common telehealth services include:

  • 99201-99215 (Office or other outpatient visits)
  • G0425-G0427 (Telehealth consultations, emergency department or initial inpatient)
  • G0406-G0408 (Follow-up inpatient telehealth consultations furnished to beneficiaries in hospital or SNFs)

Click here for a complete list.

Patient Relationship with Provider

For new* or established patients.

*To the extent the 1135 waiver requires an established relationship, HHS will not conduct audits that such as prior relationship existed for claims submitted during this public health emergency.

Virtual Check-In

What Is the Service?

A brief (5-10 minutes) check in with your practitioner via telephone or other telecommunications device to decide whether an office visit or other service is needed. A remote evaluation of recorded video and/or images submitted by an established patient.

HCPCS/CPT Code

  • HCPCS code G2012
  • HCPCS Code G2010

Patient Relationship with Provider

For established patients.

E-Visits

What Is the Service?

A communication between a patient and their provider through an online patient portal.

HCPCS/CPT Code

  • 99421
  • 99422
  • 99423
  • G2061
  • G2062
  • G2063

Patient Relationship with Provider

For established patients.

  1. Telemedicine visits are considered the same as in-person visits, and per CMS, require real-time communication between providers and patients using both audio and video.
    1. These visits are considered the same as in-person visits and are billed and reimbursed by CMS the same rate as regular, in-person visits.
    2. A complete list of covered Telemedicine services can be found here: List of Telehealth Services
  2. Virtual check-ins are brief communications between doctors and patients, such as text messaging. Providers can deliver virtual check-ins using a range of communications since they don't require both audio and video capability. CMS expects that patients will initiate most virtual check-ins by, for example, emailing their primary-care doctor.
    1. Doctors and certain practitioners may bill for these services furnished through several communication technology modalities, such as telephone (HCPCS code G2012). The practitioner may respond to the patient's concern by telephone, audio/video, secure text messaging, email, or use of a patient portal. Standard Part B cost-sharing applies to both.
    2. In addition, separate from these virtual check-in services, captured videos or images can be sent to a physician (HCPCS code G2010).
  3. E-visits involve care delivered through a patient portal, which requires providers to have a preexisting relationship with a Medicare beneficiary.
    1. The services may be billed using CPT codes 99421-99423

Both HHS and the OIG have indicated they will not conduct audits to ensure that a prior doctor-patient relationship existed for claims submitted during this public health emergency. Irrespective of that, clinicians should ensure that provider notes are adequate and consider the use of audiovisual recording to provide the necessary data to support coding and billing.

Each private payer determines its own reimbursement policy for telemedicine – always obtain prior authorization.

Additional Information

CMS has developed a Medicare Learning Network handout on telemedicine services, found here: Telehealth Service Fact Sheet

The American Medical Association (AMA) has a Quick Guide to Telemedicine in Practice resource to help mobilize remote care with implementation tips, as well as a reference to Current Procedural Terminology (CPT®) codes for reporting telemedicine and remote care services.

The AMA also offers an education module in the AMA's STEPS Forward™ that can help physicians use telemedicine in practice and the Digital Health Implementation Playbook with a 12-steps process for adopting remote monitoring of patients outside the traditional clinical environment.

Be aware that HIPAA security provisions are still in place and require covered entities that create, receive, use, or maintain a patient's protected electronic health information to protect it by using secure safeguards. Likely related to those security concerns, while the OCR has provided enhanced access to certain platforms, others have been discouraged (e.g., Facebook Live, Twitch and TikTok).