Telephone - Hoag
Please note that the information contained in this document may be privileged and confidential. This document is designed for Hoag’s Community Physicians to assist in providing answers to many of the common Telephone questions arising from the changing environment in Healthcare operations, due to COVID-19. This information is rapidly evolving as individual Payers and Health Plans determine specific guidelines around the various areas related to patient communication, clinical evaluation, coding requirements, claims processing, provider credentialing, etc. based on the original CMS 1135 Waiver. However, this FAQ may serve as a baseline document into Hoag’s physician practices to provide information surrounding the CMS waiver and operational considerations for our clients to maintain optimal outcomes, during a rapidly changing patient experience landscape, due to COVID-19.Telephone Examination – Best Practices and GuidelinesBased on Communication from DMHC under the declaration of the COVID-19 Public Health EmergencyCommercial PPO / HMO and Medicare AdvantageTelephone Visits – Established Patients OnlyIf E&M components of service and appropriate documentation New Patient99201-99205 Established Patient99212-99215If patient is established and discussion does not meet the E&M documentation guidelines/5- 10 min of medical discussion9944111-20 min of medical discussion9944221-30 min of medical discussion99443Medicare FFSTelephone Visits – Established Patients OnlyPatient E&M codes not permitted. At least 5 minutes of medical discussionG2012Telephone Visits before & after office visits: Do not bill if originating from a related E&M service provided within the previous 7 days nor leading an E&M service within the next 24 hours or soonest available appointment. Online digital E/M services CPT codes 99421-99423 can only be reported once per 7 day period, same group practice/same specialtyTelephone Visits do not meet the requirements for HCC CodingTelephone Services Coding GuidelinesPatients must be established under the practice (at least one visit in the last 3 years)Call must be personally performed and documented in the medical record by the providerEncounter must be patient-initiated via phone call or by general consentInformation discussed cannot be directly related to a prior visit (within the last seven days)Patient will NOT be seen in-person during the next 24 hoursTotal time spent on the call must be documentedVerbal Consent Verbiage should be in the note (see below)Physicians must obtain verbal consent and include the following Telehealth Verbal Consent Verbiage in the note. Hoag recommends the following verbiage: Telemedicine enables health care providers at different locations to provide safe, effective, and convenient care through technology. As with any health care service, there are risks associated with telemedicine, including equipment failure, poor images, and information security issues. You have the right to withhold or withdraw your consent to use Telemedicine at any time. Patient verbally consented to the use of telemedicine in their medical care. Note: Some EHRs have the capability to add common text and phrase short keys, consider adding a short key to automate the process for adding this verbiage. Patient LiabilityHoag is following these practices:Waiving copays for all original Medicare (Fee For Service) beneficiaries until the public health emergency endsWaiving copays for HMO/PPO plans except for Self-Insured Plans with:ICD10 diagnosis codes specific to coronavirus and COVID-19 illness (Z03.818 or Z20.828)Hoag recommends that independent providers contact Health Plans and delegated entities before following these practices.As Diagnosis may not be captured at the time of payment collection, patients should be informed that they may be liable and billed for coinsurance. If a member’s plan ID card indicates “Administrative Services Only,” the member’s plan is under a self-funded client. Self-funded plans are governed by the Employee Retirement Income Security Act of 1974 (ERISA), which is federal law. Self-funded plan sponsors?may opt out of compliance with the state mandate to waive cost-sharing for COVID-19 screening and testing. For these plans Hoag is collecting copay regardless of symptoms. Hoag is collecting Health Plan specific information, please reach out to Hoag Physician Partners (HPP.Providers@) for more information. Providing Clinical Summaries (After-Visit Summaries)The after-visit summary (AVS) is given to patients after medical appointments to summarize their health and guide future care. If properly designed, the AVS can be an educational tool to facilitate patients’ understanding of their health, reduce recall problems, and encourage adherence to self-management tasks. Hoag suggests practices leverage their Patient Portal to securely send Clinical Summaries to its patients for examinations performed via Telehealth.FAQsQ. Do I submit a charge for a telephone visit if I need to bring the patient in for further evaluation?CPT guidelines state you may not bill a 99441-9943 and G2012 telephone evaluation and management leading to an E&M Service or procedure within the next 24 hours or soonest available appointment. Q. Do I submit a charge for a telephone visit if it is a follow-up telephone call from an earlier visit?CPT guidelines state you may not bill a 99441-9943 and G2012 telephone evaluation and management originating from a related E&M service provided within the previous 7 day.Q. Will HMO/PPO plans cover telephonic only services in addition to telehealth via video + audio?Yes, to address the concerns, the health plans have heard from providers about the need to support care to patients during extended periods of social distancing they have revised their guidelines. During this time PPO and HMO plans will cover telephone-only telehealth services when appropriate. These services are reported with the appropriate E/M codes 99201-99215 supported by provider documentation of history, exam, MDM.Exceptions include: chiropractic services, physical, occupational, and speech therapies. These services require face-to-face interaction and therefore are not appropriate for telephone-only consultations. Q. What is the reimbursement rate for telehealth and telephonic services?PPO/HMOs – due to recent changes, as required by the State of California, telehealth and telephonic services must be paid at the same rate, whether a service is provided in-person or through telehealth or telephonically, if the service is the same regardless of the modality of delivery, as determined by the provider’s description of the service on the claim.CMS has not made these changes. Telephone only visits for these payers are still reported with code G2012.Q. We have heard conflicting information about whether Telehealth Visits billed with E/M codes 99201-99205, 99212-99215 can be provided via Telephone only? Due to recent changes, all Telehealth Visits for PPO/HMO patients can be billed with E/M codes 99201-99215 when performed using two-way audio and video or by telephone only communication. These changes were made on March 23rd after new information was released by the DMHC.CMS has not made these changes. Telephone only visits for these payers are to be reported with code G2012.Q. How can a physician or qualified health professional generate an E&M code from a telephone examination? Telephone exams can be challenging to generate E&M components of service and documentation. Below are some examples of what exam elements may look like:patient is speaking full sentencespatient is alert and orientedmood and behavior appropriateno signs of distressno wheezing heardaudible congestion in his voicecoughing on the phoneIf the patient has the appropriate equipment at home (i.e. Blood pressure monitor, scale, HR monitor, etc.) the physician can verify the reading/value and document this in the note under the exam.? Please notate that the patient took their vitals on their own equipment and you verified the reading/value.Also, remember established patients only require 2 of the 3 key components to be documented to bill for the level of service (99212-99215), so if your exam is minimal or unobtainable you can base your E/M on History and Medical Decision Making.Q. If I conducted a telephone (no video) visit for an HMO patient but met the elements to qualify for an E/M visit, should I bill for a Telehealth E&M service or the 99441-99443 telephone visit codes? Telephone only visits (HMO or PPO payers) would be billed with the appropriate CPT codes 99201-99215 when the required elements (History, Exam and MDM) are documented.Q. If I conducted a telephone (no video) visit for a Medicare FFS patient but met the elements to qualify for an E/M visit, should I bill for a Telehealth E&M service or with the telephone visit codes 99441-99443 or G2012? Medicare FFS telephone only visits are coded with G2012. These payers do not allow Telephone visits to be reported with CPT codes 99201-99215 or 99441-99443.Q. What codes would be appropriate to consider for a telehealth or telephonic visit?PPO/HMO Plans - telehealth or telephonic services should billed with the same CPT codes that they would normally bill for in-person visits with a modifier GT and Place of Service (POS) code “02”. If a different modifier is required due to individual plan requirements, the correction will be done on the back end.CMS has not made these changes for Medicare FFS. Telephone only visits for these payers are still reported with code G2012.Q. Can you report CPT code 99441 or G2012 for a Telephone visit that was less than 5 minutes?No, if the specified time requirement is not met, it is a non-billable service. Both CPT codes 99441 and G2012 require at least 5 minutes of medical discussion. If at least 5 minutes of medical discussion was not provided you would report the service with code 99499 - N/C visit.Q. Can Telephone Visits (CPT Codes 99441-99443) be provided to new patients? And will all payers cover these codes?No, these Telephone visit codes can only be provided to established patients.Report Telephone only visits based on time or when the key components of an E/M service are not documented in the note (history, exam, MDM) with CPT codes 99441-99443. For Medicare FFS report Telephone calls with code G2012Q. Can Telephone Evaluation and Management Visits be provided to new patients? Telephone calls and online evaluations are still for established patients only. Under normal circumstances new patient visits via Telehealth (two-way audio/visual) would not be covered by CMS or other health plans. However, due to the COVID 19 health emergency New Patient visits (CPT codes 99201-99205) may be performed and reported through telehealth NOT telephone (audio-only). Q. Does any other modifier i.e. 95, GQ need to be added for Telephone visits?Hoag’s current workflow is to add modifier GT, if a specific payer requires 95 or other modifier, Hoag will correct it on the back end. Please check with your IT and Revenue Cycle Services on your system configuration.Q. Does Place of Service need to be added for Telephone visits?Our current workflow links the Correct Place of Service (02) for telehealth or telephone within the Appointment Type. This does not need to be noted in the documentation. Please check with your IT and Revenue Cycle Services on your system configuration.Q. What if the patient calls on multiple days, can these visits be billed each day? It is important to look at the description/definition of each code. Some codes do not define limit on how many times per week a code can be billed, and some are defined as cumulative and to be coded and billed only once a week. ................
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