Society Continues to Address Telehealth Questions/Concerns

Given the potential for spread of coronavirus in nursing facilities by clinicians who visited multiple facilities, telehealth has become a valuable tool to take care of patients—and there have been a lot of questions on how to use it and how to bill for it. At last week’s Virtual Annual Conference, the Society held a number of coding/telehealth sessions that focused on this topic and answered a number of questions from attendees. Anyone who missed those sessions can access the recordings as part of their registration; if you didn’t participate in the conference the recordings are available for purchase.

The Society is planning to host another question and answer session on the topic in the near future. Meanwhile, a few popular questions and answers are included below:

Q: Can I do an initial visit using telehealth?

A: Yes, nursing facility CPT codes 99304-99306 for initial visit; 99307-99310 for subsequent care visit; and 99315/16 for nursing facility discharge have all been added to Medicare covered telehealth visits

Q: Can I do nursing facility visits by phone only?

A: No, if you are billing a code on the Medicare telehealth list, those services are defined as audio and visual technology. This is getting confused with a separate service described by CPT codes 99441-99443 that are telephone only evaluation and management services that could potentially be used in lieu of CPT nursing facility codes. Read this for more information.

Q. Do I need a modifier to bill for telehealth and what place of service should I use?

A: The Centers for Medicare & Medicaid Services (CMS) encourages physicians to bill the telehealth service with the Place of Service (POS) code they would have used if the service had been provided in-person and append CPT modifier 95 (“Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications System”) to the claim lines that describe services delivered via telehealth. This was changed from previous CMS communication but is the latest information. CMS encourages clinicians to do this because payment for telehealth services is at the same Medicare rate as face-to-face. If you append it with a telehealth modifier, those services are reimbursed at a lower rate.

Q: Has CMS suspended regulatory visit requirements?

A: No, CMS suspended the requirement that those visits must be done face-to-face. Therefore they can be done via telehealth.

Q: Can the nursing facility get paid for using telehealth services?

A: Yes, there is an originating site fee the facility can collect for telehealth. The facility can then bill HCPCS code Q3014.

During the conference, Society leaders suggested that it is still important to stay engaged with facilities for many reasons and it may not be appropriate to do all visits via telehealth. Clinicians need to make sure they are balancing their own safety as well as those of patients and residence with the clinical needs in the facility. It may also be important to be present in the facility to work with staff in the buildings. However, everyone must assess the situation and have a coordinated plan that will ensure safety and appropriate clinical care of patients and residents.

We will continue to update our materials as CMS releases more information. Please visit the Society telehealth resource page for more information.