Part 2 – Know your CPT, Modifier, and Place of Service Rules
In this edition, we would like to provide some quick reference of applicable CPT codes to represent Telehealth Services and related guidelines associated with appropriate reporting of Modifiers and Place of Service (POS).
The CPT Crosswalk to Coding Telehealth and Other Virtual visits
The table below provides a quick lookup of various CPT-4 (Current Procedural Terminology, 4th Edition) code sets available to report Telehealth Services and other forms of virtual visits. Please refer to CPT 4 for a complete description of these code sets to ensure every part of the documentation requirement is met while assigning a code.
Patient Consent and Documentation Requirements
It is recommended to have the Patient consent (can be verbal) documented in the medical record for a Telehealth Service offered. The consent can as well be taken by an auxiliary staff under the supervision of a physician or other qualified healthcare professional.
For the duration of PHE, CMS has waived the requirement of a written order from a treating physician or NPP (Non-Physician Practitioners) for COVID-19 related diagnostic tests, influenza tests, and any other laboratory tests required to confirm or rule out COVID-19 diagnosis (subject to state requirements for ordering diagnostic tests).
The documentation requirements for Telemedicine Clinical visits have not changed, including the time-based coding requirements. CMS is however, making allowances during the Public Health Emergency to report E/M services weighed based on Medical Decision Making or basis time spent with the patient irrespective of counseling dominating the time spent on the visit. Individual Payor specifics apply.
Role of Modifiers
CPT Modifiers…
Modifier 95 - Telehealth services by a qualified Provider are reported with this modifier (Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications System)
Modifier 32 - To show a third party mandated that the Provider perform the service.
Other applicable HCPCS Modifiers…
GT Modifier - Via interactive audio and video telecommunication systems
GQ Modifier - Via asynchronous Telecommunications system. Part of Federal Telemedicine Demonstration Project in Alaska and Hawaii
CS Modifier - Cost-sharing for specified COVID-19 testing-related services that result in an order for or administration of a COVID-19 test
CR Modifier - Catastrophe/disaster related
G0 (G-Zero) Modifier - Telehealth Services for Diagnosis, Evaluation, Or Treatment, Of Symptoms of An Acute Stroke
Modifier 95 vs. GT - Unlike GT, Modifier 95 was originally limited to codes outlined in Appendix P of CPT 4 before the PHE. CMS will now allow more than 80 additional services furnished via Telehealth to be reported along with Modifier 95. There are few payors that still mandate the use of a GT modifier instead of 95 (Individual Payor specifics apply).
Place of Service (POS):
The choice of POS is usually equal to what it would have been in the absence of a PHE meeting the requirements of an in-person visit. CMS has now allowed reporting POS 11 (Office), 22 (Outpatient Hospital), etc., for Telemedicine visits; however, few payors still prefer a POS 02 (Telehealth).
Coding Preventive Services
CMS has allowed Initial and Subsequent Annual Wellness visits (G0438 & G0439) to be covered via Telemedicine; however routine Preventive services (99381-99397) are not covered by most payors.
New CPT and HCPCS Codes to represent Testing, Proprietary Laboratory Analyses, and Specimen collection for COVID-19
While we are on war footing to battle the pandemic, the most important step is to identify the type of infection. Appropriate reporting of these multiple testing requirements, therefore, becomes pivotal. There are new CPT and HCPCS codes introduced by CMS and AMA to capture these multiple categories of testing services in place.
CMS allows CPT 99211 to be used for representing specimen collection by clinical staff (e.g., RN – Registered Nurses /LPN – Licensed Practical Nurses/MA – Medical Assistants) for both new and established patients during the PHE incident to Supervising Physician Services along with CS modifier.
In our upcoming edition, we will throw light on Diagnosis Coding associated with COVID-19, Payor specifics, and real-time Case Studies. See you in the next edition….
About the Authors
Rahul Bhalerao MSc. CPC, CPMA comes with 9+ years of hands-on coding expertise across multiple specialties. As a Group Leader with Access Healthcare, Rahul supports Prospective Coding and Denial management services that include having a close tab on denial trends, Physician coding Audits alongside education.
Jestin David, CPC carries 8+ years of Medical billing and coding expertise with multi-specialty Evaluation and Management services. As a Group Leader with Access Healthcare, Jestin is responsible for Coding audits and Remote Physician Education Services focusing on clinical documentation improvement.
Siva Kumar, CPC, COC, CCS-P carries over 10 years of Multi-Specialty coding and training experience. As a coding trainer, Sivakumar assists with continuous coding education needs internally at Access Healthcare in addition to assisting domain needs with new coding Transitions.