Ask an Auditor: Telehealth in the Time of COVID - FAQ, Part 4

Welcome back to our final installment of our Q&A on Telehealth in the Time of COVID. If you’re just catching up, you can read all of our previous entries here:

Part 1

Part 2

Part 3

I’ve really enjoyed all of the great questions I've received, and hope that my answers have helped to bring clarity to a topic we’ve all been scratching our heads over every day since the pandemic.

If those of you reading have any additional questions, be sure to leave them in the question and comment section below. Otherwise, thanks for reading! I hope you’re all staying safe out there.

Question 1:

Do you know until when CMS will keep covering telehealth benefits?

Answer 1:

I sure wish we did, but they have not released a date as of 6/15/2020.

Question 2:

Can you please give an example of the difference between G2012 and 99441?

Answer 2:

Sure, here are two:

  1. G2012: The provider calls the patient to see how they are doing.
  2. 99441: The patient is having health issues and needs to see the provider, but does not have video capabilities.

Question 3

Can you provide a link to the program that will assist with determination of how many charts you should audit?

Answer 3:

You can find it at OIG RAT-STATS:

Question 4:

Does the 7 day rule apply to a phone-only visit within the last 7 days for the same CC? Also, how do you count the 7 days (e.g. phone visit 5/12 and 5/19)?

Answer 4:

For phone visits, the 7 days rule applies to ALL services for the same CC, even procedures (per the CPT guidelines).

The guidelines are for the previous 7 days. In your example, the 5/19 visit can only be billed if it’s not related to the 5/12 visit, because that is in the previous 7 days.

Question 5:

Can Residents in a GME Teaching Facility bill without the Faculty adding GE/GC modifiers? We are getting denials and wanted to confirm if billing is allowed without the teaching modifiers GE/GC. Thanks!

Answer 5:

For Medicare, my understanding is that these modifiers still apply, but I would put them after the 95 modifier. This topic was recently clarified by CMS, so it may just be that they need to reprocess it. If it's a different payer, you'll have to reach out to them to question the denial.

Question 6:

To document patient initiation for phone calls, is it enough to include a patient consent?

Answer 6:

Yes. As an auditor, I would prefer to see both. But at minimum, the consent works.

Question 7:

Should those of us in rural health settings use G0071, or G2025 for virtual check-ins?

Answer 7:

Yes. And there is a great MLN Matters article that describes why in more detail, which you can find here.

Question 8:

When documenting for SNF/NF telemedicine visits, nothing has changed, correct? It is not allowed to bill based on MDM/Time spent? It still needs the 3 components and/or a timestamp with at least 50% time counseling patient on x,y,z?

Answer 8:

Correct, you cannot level SNF/NF telemedicine visits by MDM or time only. You still must use the 3 key elements or the correct time verbiage.

Question 9:

Can an outpatient telemedicine consultation be billed based on time? If Medicare it would crosswalk to new patient code.

Answer 9:

For Medicare, you are basically billing a new patient E/M for these, so use MDM or time. For other payers, you'll have to see if they allow consultations to be leveled using only MDM/time.

Question 10:

What is the correct coding for phone visits? Is it incorrect to bill the corresponding E/M, versus the telehealth phone code?

Answer 10:

Phone calls are billed with 99441-99443. It would be incorrect to bill an E/M if no video was used.

Question 11:

Is CMS allowing the IPPE (G0402)? And can you point me to the CMS documentation if they are? (Even though we’re instructed not to, some physicians have and our MAC originally denied them, and then came back and paid.)

Answer 11:

No, G0402 is not listed on the list of applicable services. If these were truly done via telehealth, you should contact your MAC to see why they paid them. If you did not apply modifier 95, they would have paid them thinking they were not telehealth. Follow this link for the list.

Question 12:

Are MD's allowed to bill subsequent hospital visits (after an admission) by phone?

Answer 12:

Subsequent hospital inpatient visits are listed as telehealth services, but they MUST be done via video. Telephone-only is not allowed.

Questions or Comments?