Ask an Auditor: Telehealth in the Time of COVID - FAQ, Part 3

Hello my fellow auditors and coders, and welcome back to our ongoing Q&A on Telehealth in the Time of COVID. After delivering this round of answers, there’s only one more blog post to go, which I’ll post next week - so keep any eye out for it.

Before I begin, I wanted to say hello to anyone who might be reading this series for the very first time. If this is in fact your first time reading our ongoing series, you can find the Q&As to Part 1 here, and Part 2 here.

Now, let’s dive in.

(Editor's note: Some questions have been lightly edited for clarity.)

Question 1:

If I have a provider that does a telephone visit, but that provider is a resident, and the attending provider was not on the call (the note usually states the attending was in the office but not in the room with the resident during the call), is this a billable service?

Answer 1:

No, residents alone cannot bill, except at a Patient Care Encounter (PCE.)

Question 2:

During the webinar, you mentioned that we can use time from the current CPT book, not the time in 2021 for video office visit. Is this correct?

Answer 2:

Time is the minutes mentioned in the 2020 CPT book for that code (ie: 99213 = 15 minutes). Do not use the time sheet referenced in the Federal Register originally. 2021 time will be different, though we cannot use it until then.

Question 3:

Are there any frequency restrictions on telehealth visits in a specific time?

Answer 3:

Only for e-visits, which are cumulative over 7 days, and the telephone visit guidelines, as per the CPT book.

Question 4:

What happens if the video portion of a telehealth visit cuts out during the encounter. Can you still code the office visit?

Answer 4:

CMS states that you should bill the code that relates to the biggest part of the visit. If most of the visit was completed via video, you would be OK to bill as a video visit. If hardly any video is used, you'll need to bill a telephone visit.

Question 5:

Can preventive services be billed via telephone or video?

Answer 5:

You’ll need to check with your payer and Medicaid payer. Most of them are allowing preventative services to be billed via telephone or video, but have rules around them (e.g., a minimum age, or whether or not they need vaccines.) However, CMS does not pay preventive medicine codes.

Question 6:

Medicaid said 99211 can be used by RNs for over-the-phone COVID-19 screening. Are other payers also allowing this?

Answer 6:

As long as the nurse documents the medical necessity of the E/M, on top of the covid test itself (if performed onsite), then yes, it should be payable.

Question 7:

Wasn't the rule about the telephone being related to E/M in the past 7 days, or in the next 24 hours, relaxed during COVID?

Answer 7:

No, this rule still holds true during the COVID-19 pandemic.

Question 8:

What recommendation do you have for documenting time? Do you document separate start and stop times, or just total time for each task or for a day? For example, I spent 25 minutes with the patient, then spent 20 minutes reviewing outside records after the appointment, then 15 minutes coordinating referral for orthopedics.

Answer 8:

The guidelines state you only need the total time documented. I always recommend both start and stop times, then the total time spent for that patient.

Question 9:

Time is not based on greater than 50% counseling/coordination, rather it is based on all of the time spent on the day of the encounter. What would you expect to be documented in regard to time (i.e. specific on record/lab review, discussion with another provider, etc.)?

Answer 9:

For CMS, that is correct. Some payers may not allow only the total time and are still relying on the counseling being greater than 50%. Only the total time needs be documented for CMS purposes. That said, remember this is only for office new- or established-patient codes.

Question 10:

Should phone calls be billed by time (like Medicare) when using CPT 99211-99214, per insurance request to bill calls as EM codes?

Answer 10:

No, unless the payer states otherwise. We still hold that the 3 key elements, or greater than 50%, were spent in counseling to be true for payers, unless specifically told otherwise.

Question 11:

What about Annual Wellness Visits? I know that they are allowed to be done with a Video Visit, but what is your suggestion about having the patient fill out their questionnaire (which is required by some payers)? Should we mail them prior to the appointment, and is it necessary that we document that we did that?

Answer 11:

You could have the patient mail it or submit via a secure portal if possible. Also, I’d recommend researching tools on the internet, so patients can fill out and submit online.

Question 12:

Doesn't the patient location need to be documented - just in case the originating fee (Q3014) is billed?

Answer 12:

I always recommend documenting the patient location, but it is not currently stated as being required.

Question 13:

For a podiatry visit, what is proper code for seeing a patient at a nursing home, and for seeing a patient at assisted living home, and for seeing a patient at their home?

Answer 13:

Assuming CMS, you will bill the code for the site that the patient is located. For example, a SNF visit might be 99307-99310 (for a subsequent visit), while home patients are usually 99212-99215.

Question 14:

Are virtual and telephone visits for office and outpatient services only? Or can they be used for inpatient visits as well?

Answer 14:

For CMS, the inpatient services are not allowed to be performed with telephone only. However, they can be video.

Question 15:

What about charges that were documented and billed prior to all these new regulations being implemented (e.g., missing time or consent)?

Answer 15:

This is a tough question to answer. You'll have to do some analysis to figure out if it's worth it to resubmit the claims as corrected claims in order to receive additional payment. Perhaps your payer would allow you to do an extrapolation, or submit one bulk corrected claim. Or, if you audit and realize a lot of your claims were incorrect, then you'll have to submit them for overpayment.

Questions or Comments?