An April 2018 OIG report on telehealth claims revealed CMS has agreed to conduct periodic post payment reviews and implement claim edits directed at this emerging area. To help your medical coding skills keep pace, here are some pointers on CPT® and Medicare telemedicine coding.
Telemedicine CPT® Codes: Start With the Official AMA List
The AMA, which holds copyright in CPT®, designates CPT® codes that you may use to report synchronous (meaning real-time) telemedicine services. To indicate to a payer that the service was a telemedicine service, you append telemedicine modifier 95 (Synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system).
Note that the descriptor for the telemedicine modifier indicates the use of interactive audio AND video telecommunications, so you must use both.
You should make sure you have an updated list of telemedicine CPT® codes each year so you can identify the services you perform that are on the list. For instance, you may not be surprised to learn there are many E/M codes on the list. But 2018 CPT® telemedicine procedure codes also include codes like these:
- 92227 (Remote imaging for detection of retinal disease (eg, retinopathy in a patient with diabetes) with analysis and report under physician supervision, unilateral or bilateral)
- 93272 (External patient and, when performed, auto activated electrocardiographic rhythm derived event recording with symptom-related memory loop with remote download capability up to 30 days, 24-hour attended monitoring; review and interpretation by a physician or other qualified health care professional).
Telemedicine Medicare Codes: Tune In to Payer Requirements
If telemedicine reimbursement is your concern, you should be aware that a payer’s list of covered telemedicine billing codes may not line up with the AMA’s list. And beyond that, the service is likely to have to meet a long list of requirements before it’s eligible for payment.
Medicare provides a good example. For instance, the 2018 list of Medicare Telehealth Services differs significantly from the AMA list. One major reason is that Medicare adds HCPCS G codes to the list of telemedicine/telehealth codes.
Medicare’s telemedicine/telehealth reimbursement policies also specify that the originating site must be in one of these locations:
- A county outside a Metropolitan Statistical Area
- A rural Health Professional Shortage Area in a rural census tract.
Don’t miss: An entity participating in a federal telemedicine demonstration project approved or funded by HHS also qualifies as an originating site. Those entities should be sure to review and follow the additional requirements and rules that apply to them.
Caution: The actual originating site needs to be one authorized by law, specifically one of these:
- Community Mental Health Center
- Critical Access Hospital
- Federally Qualified Health Center
- Hospital-Based or CAH-Based Renal Dialysis Center (including satellite)
- Physician or practitioner office
- Rural Health Clinic
- Skilled Nursing Facility
Warning: A patient’s home is not an authorized originating site, and independent renal dialysis facilities are not eligible either.
Reporting rules: Medicare telemedicine services come with specific reporting rules, too, so be sure you know the ones that apply to you. Here are a few to keep in mind:
- Distant site practitioners should submit telehealth claims using place of service 02 (Telehealth).
- Alaska and Hawaii participants in federal demonstration telemedicine programs are allowed to use asynchronous telecommunication systems. To show an asynchronous medical file came from one of those okayed participants, append modifier GQ (Via asynchronous telecommunications system) to the service code.
- Distant site practitioners billing under the CAH Optional Payment Method submit institutional claims using modifier GT (Via interactive audio and video telecommunication systems).
- Originating sites should report Q3014 (Telehealth originating site facility fee).
Resources: Keep Telemedicine Codes Close at Hand
You will find the AMA telemedicine codes in the printed CPT® manual, marked by a star and listed in an appendix. If you use online code search, telemedicine codes may be identified there, too. You also can choose a data file featuring telemedicine codes (AMA and/or Medicare) to integrate with your own existing systems so you can immediately identify eligible codes. Just be sure to update your resource each year so you have the current list of codes, and keep payer-specific rules in mind when you finalize your claim.