2.24.23 Optimizing Telehealth Billing- Current Telehealth CPT Codes & Telehealth Reimbursement Strategies .pptx
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2.24.23 Optimizing Telehealth Billing- Current Telehealth CPT Codes & Telehealth Reimbursement Strategies .pptx
- 1. Optimizing Telehealth Billing: Current Telehealth CPT Codes & Telehealth Reimbursement Strategies
- 2. Marlene M. Maheu PhD • Executive Director of Telehealth.org (formerly TBHI) • Founder of the Journal for Technology in Behavioral Science (JTiBS) • Founder / CEO of the Coalition for Technology in Behavioral Science (CTiBS) • More than 100 hours of digitized telebehavioral health training focused clinical, legal & ethical risk management & compliance • Served on a dozen professional association committees, task forces, and workgroups related to establishing standards and guidelines for telebehavioral health • Published 50+ peer-reviewed telehealth book chapters & journal articles • Lead author of five telehealth textbooks.
- 3. And there’s you! Please introduce yourself with state, profession and specialty.
- 4. © 1994-2023 Telehealth.org, LLC All rights reserved. • Identify the current telehealth CPT codes and other current telehealth billing strategies. • Describe what to do if you are not paid for your telehealth sessions. • Outline where to go to get free and accurate information about telehealth billing. Learning Objectives 4
- 5. © 1994-2023 Telehealth.org, LLC All rights reserved. • Slide and recording access 24/7 for 6 months. Login is required. Please respect our copyright. • We will continue in audio-only mode throughout the hour. • Please interact in chat box as I speak, but stay on topic. • My goal is to have a conversation with you yet cover as much ground as possible. • Questions asked in the course Discussion Forum will be addressed first. • I will stay for as long as it takes after the hour to answer everyone’s questions. Telehealth.org Training 5
- 6. © 1994-2023 Telehealth.org, LLC All rights reserved. • LIVE CME or CE if you arrived within 15 min. of start, stay the entire time, interact AND complete the post-test by midnight today. • Otherwise, you will receive a course completion that awards you asynchronous course credit hours. • Social workers are invited to participate but will not obtain CE for this hour. Telehealth.org Training 6
- 7. © 1994-2023 Telehealth.org, LLC All rights reserved. • I will not read all slides. Rather, I will show you where resources are, briefly outline their contents and invite you to review at your discretion. • Print handout ahead of time to take notes. Font size options are available. • You are automatically enrolled into our in- house community news mailings. You can unsubscribe at any time. • Lock your door, turn off your phone/email, and strap yourself in - we are about to get focused on Optimizing Telehealth Reimbursement Telehealth.org Training 7
- 9. Coalition for Technology in Behavioral Science (CTiBS) An Interprofessional Framework for Telebehavioral Health Competencies (2018)
- 10. © 1994-2023 Telehealth.org, LLC All rights reserved. CTiBS TBH Competency Domains (We will look at 3 today) Clinical Telepresence Technical mHealth Ethical & Evidence-Based Legal & Regulatory Practice Development 7 Domains An Interprofessional Framework for Telebehavioral Health Competencies
- 12. © 1994-2022 Telebehavioral Health Institute, LLC All rights reserved. Private Payers (179M, 2021) Medicaid & Children’s Health Insurance Program (CHIP) (91M Americans, 2022) Grants Medicare (62.8M Americans, 2020) 12
- 13. Private Payers (aka “Commercial Payers” or “3rd Party Payers”)
- 14. © 1994-2022 Telebehavioral Health Institute, LLC All rights reserved. Typically follow the lead set by CMS over time Parity – mandated payment is on par with in-person care Payors cover different codes in different states Payors often “test” CPT codes in different states Some states require reimbursement for telehealth services 14 Private Payers Write to each payer to ask for their covered CPT & modifier codes
- 15. © 1994-2022 Telebehavioral Health Institute, LLC All rights reserved. Always communicate in writing Some companies will not respond to written inquires Try billing one session to get a written response Payment can depend on state definition of “telehealth” Some carriers don’t follow the law 15 Private Payers Write to each payer to ask for their covered CPT and modifier codes
- 18. © 1994-2023 Telehealth.org, LLC All rights reserved. 18 • Contact carrier in writing, ask questions – document well • Contact your national and state professional associations – many have lobbyists • Call another billing office • Speak with telehealth consultant • Speak to a regional Telehealth Resource Center • Contact the Center for Connected Health Policy • Contact state insurance commissioner • Share your experience in any related Telehealth.org blog article for other readers to benefit What can you do if a payer won’t pay for legitimate and correctly coded telehealth services? s
- 19. Medicaid & CHIP
- 23. © 1994-2023 Telehealth.org, LLC All rights reserved. 23 https://blog.telehealth.org/st ates-reimburse-many- aspects-of-medicaid- telehealth-without-federal- approval/ Medicaid Telehealth Coverage Study by Kaiser Family Foundation
- 25. © 1994-2023 Telehealth.org, LLC All rights reserved. 25 • All 50 states and the District of Columbia have some form of Medicaid reimbursement for telehealth in their public program. • Research licensure requirements established by payer – you may need to be in the state whose citizens you are serving through Medicaid What other issues should I know about Medicaid paying for telehealth?
- 26. Medicare
- 31. © 1994-2023 Telehealth.org, LLC All rights reserved. 31 • Clinician’s feet must be on US soil when billing Medicare. • Aside from that, Medicare does not establish licensure requirements. Such requirements are set by state licensing boards. What other issues should I know about Medicare paying for telehealth?
- 32. Grants
- 34. Types of Providers Eligible for Reimbursement
- 35. © 1994-2023 Telehealth.org, LLC All rights reserved. 35 • Private Payers - depends on carrier, state & profession • Medicaid – depends on state • Medicare - physicians, nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologists, clinical social workers, registered dietitians, and nutrition professionals. • Grants – depends on grant Who can get paid for telehealth services? s
- 36. © 1994-2023 Telehealth.org, LLC All rights reserved. 36 January 1, 2024 See: Medicare and Medicaid Programs; CY 2023 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies Included in your “Documents” for this course. When will addiction professionals, counselors and MFTs be eligible for reimbursement by Medicare? s
- 38. © 1994-2023 Telehealth.org, LLC All rights reserved. 38 How to Search Documents Search for the words: “telehealth” or your profession, such as “Social work” by clicking “Control F” or Command F” on your keyboard
- 39. CPT Codes
- 40. © 1994-2023 Telehealth.org, LLC All rights reserved. 40 • Medicare Physician Fee Schedule (MPFS) is released by the Centers for Medicare and Medicaid Services (CMS) in December • Outlines the fees to be reimbursed to licensed healthcare professionals in the US. • Telehealth.org keeps its community informed through its blog Changes in the 2023 Physician Fee Schedule s
- 41. © 1994-2023 Telehealth.org, LLC All rights reserved. 41 • Yes, for most carriers • In many states, the law requires insurance companies to pay at the same rate as in- person (known as ”telehealth parity”) • If you work for online employers, they often pay approximately $30 for hour • If you work for private telehealth provider panels, your rate can be higher than $30 per hour Are telehealth billing rates the same as for in-person service delivery?
- 42. © 1994-2023 Telehealth.org, LLC All rights reserved. 42 • 9-codes often used by private payers • Not all payers will use the same codes • Payers will often pay for one code and not another • by American Medical Association (AMA) • G-codes used by Medicare, Medicaid and CHIP (CMS) • Grant programs may not use the CPT coding system at all • It is essential that you check with each payer in writing to ask which codes they cover for telehealth Which CPT Codes Are Used by Which Payers? * Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 43. © 1994-2023 Telehealth.org, LLC All rights reserved. 43 Modifier codes • 95 - CPT Telehealth Code Modifier • 11 - Place of Service (POS) What are the other types of codes used for telehealth service? * Telehealth.org Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 45. © 1994-2023 Telehealth.org, LLC All rights reserved. 45 10 - Place of Service (POS) code 95 - for Telehealth after the CPT or HCPCS code 5 Character CPT or HCPCS code Telehealth
- 46. • 98966-98988 - CPT codes for tele-therapists are for “telephone assessment and management services” provided to an established patient • Codes may not originate from a related assessment and management service provided within the previous 7 days • The codes may not lead to an assessment management service or procedure within the next 24 hours or soonest available appointment • Codes are to NOT be used for traditional psychotherapy by telephone • The codes apply only when the patient calls the provider • “Assessment and management” does not mean formal testing • * Liability Disclaimer: Verify all billing codes with your billing professional(s) Audio-Only Telephone Services 46
- 47. © 1994-2023 Telehealth.org, LLC All rights reserved. 47 • 99441 CPT Code – used for audio- only, but the 2023 Medicare Physician Fee Schedule made it clear that non-behavioral health providers will not be paid for audio- only telehealth after the PHE • 93 – To be used by behavioral professionals to the end of the PHE • FQ – to be used by behavioral professionals for audio-only services with clients or patients at a distant site after PHE (check w/ payers) • See your “Documents” file this Telehealth.org training Audio-Only (Telephone Telehealth) Code 99441 CPT Code rather than the 93 Modifier FQ? * Telehealth.org Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 49. © 1994-2023 Telehealth.org, LLC All rights reserved. 49 Same as in-person. For example: • CPT 90832 - Psychotherapy for 30 Minutes • CPT 90834 - Psychotherapy for 45 Minutes • CPT 90837 - Psychotherapy for 55+ Minutes What are the CPT codes for tele-therapy or telebehavioral health? * Telehealth.org Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 50. © 1994-2023 Telehealth.org, LLC All rights reserved. 50 • Assessment is a term used in many billing codes for in-person care as well as when services are delivered in-person. • Most psychological testing and assessment codes for telehealth are the same as when services are delivered in-person. (Just use in- person codes.) Are there telehealth- specific assessment codes? * Telehealth.org Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 51. © 1994-2023 Telehealth.org, LLC All rights reserved. 51 • CPT 99483 - Cognitive Assessment and Care Planning Services • CPT 99334-99335 - Domiciliary, Rest Home, or Custodial Care services, Established patients Home Visits, Established Patient; developed to provide reimbursement for comprehensive evaluation of a new or existing patient, who exhibits signs and/or symptoms of cognitive impairment, is required to establish or confirm a diagnosis, etiology and severity for the condition. What are examples of cognitive assessment codes? * Telehealth.org Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 52. © 1994-2023 Telehealth.org, LLC All rights reserved. 52 CPT 96127 - Telehealth Behavioral Assessment • Use in primary care offices and other integrated care centers • Can reimburse almost $25 per administration and are billable up to four times per year for the same individual. • Has been approved by the Center for Medicare and Medicaid Services Administration (CMS) since 2015 for remote evaluations What is a “Telehealth Behavioral Assessment?” * Telehealth.org Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 54. © 1994-2023 Telehealth.org, LLC All rights reserved. 54 • CPT 90791 - Integrated biopsychosocial assessment, including history, mental status, and recommendations • Evaluation may include “ communication with f amily or other sources and review and ordering of diagnostic studies” What are other specific assessment billing codes? * Telehealth.org Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 55. © 1994-2023 Telehealth.org, LLC All rights reserved. 55 • 99453 - Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education for the use of equipment. • 99454 - Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), initial; device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days. • 99457 - Remote physiologic monitoring treatment management services, 20 minutes or more of clinical staff/physician/other qualified healthcare professional time in a calendar month requiring interactive communication with the patient/caregiver during the month. Which codes can be used for remote patient monitoring (RPM)?* * Telehealth.org Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 56. © 1994-2023 Telehealth.org, LLC All rights reserved. 56 • CPT 90846 • CPT 90847 Which codes can be used for family therapy?* * Telehealth.org Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 60. © 1994-2023 Telehealth.org, LLC All rights reserved. 60 ** Included in your “Documents”file for this course
- 61. © 1994-2023 Telehealth.org, LLC All rights reserved. 61 • Telephone CPT G2252 or bill as you would in-person • Family therapy CPT 90846 (without pt.) & CPT 90847 (with pt.) • Telesupervision – “Incident to” through the PHE • Virtual Check-Ins CPT G2012 • Remote patient monitoring (RPM) Code 99091+ Others What are the specific billing codes for telehealth?* * Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 62. © 1994-2023 Telehealth.org, LLC All rights reserved. 62 • No clear CPT code for “Telesupervision” • Telesupervision covered “Incident to” through the PHE • 99449 as maintained by American Medical Association, is a medical procedural code under the range -Interprofessional Telephone/Internet/Electronic Health Record Consultations What are the specific billing codes for telehealth?* * Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 63. © 1994-2023 Telehealth.org, LLC All rights reserved. 63 • CPT 90853 – Group Intervention • CPT 96165 (Group Intervention for each additional 15 minutes) What are the specific billing codes for group telehealth?* * Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 64. Four Little-Used Telehealth- Specific Billing Codes
- 65. © 1994-2023 Telehealth.org, LLC All rights reserved. 65 What is an E-Visit? E-Visits are non-face-to-face services conducted online, or through email, text, telephone, electronic health record (EHR) portal messages or other HIPAA-compliant, secure platforms. They are also known as “online assessment and management services” that require the professional to assess and make decisions about answers to further manage the patient. They are always patient-initiated.
- 67. © 1994-2023 Telehealth.org, LLC All rights reserved. 67 Who Initiates an E- Visit? E-Visits are always patient-initiated. They can involve the time needed to: • Review the initial inquiry • Review records • Interact with clinical staff about the patient’s question • Development of a management plan • Involves feedback on functioning, treatment changes and planning for monitoring and follow-up • Subsequent digital communication online, email, texting, telephone, etc.
- 68. © 1994-2023 Telehealth.org, LLC All rights reserved. 68 E-Visit Details • Must be more than five minutes. • Report e-visit services once per seven-day period. • Do not count G2061, G2062 or G2063 time otherwise reported with other services. • Do not use e-visit service codes if the initial inquiry from the patient comes within seven days of a previous treatment or service that both relate to the same problem. What are the details related to E-Visit Codes? * Telehealth.org Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 69. © 1994-2023 Telehealth.org, LLC All rights reserved. 69 E-Visit Details • Do not use e-visit service codes if the initial inquiry from the patient occurs within the post-treatment period of a previously completed procedure. • If the initial inquiry from the patient comes within seven days of another treatment or assessment service, you can only use e-visit service codes if the inquiry addresses a different problem. • If the patient presents a new, unrelated problem within the seven- day period of an e-visit service, add time spent on the assessment and management of the additional problem to the cumulative service time. What more do I need to know about E-Visit Codes? * Telehealth.org Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 70. © 1994-2023 Telehealth.org, LLC All rights reserved. 70 E-Visit Details • Can be covered by some payers and not others. • Confirm access to these codes with all involved payers prior to using. What more do I need to know about E-Visit Codes?
- 71. © 1994-2023 Telehealth.org, LLC All rights reserved. 71 E-Visit Codes • G2061- Qualified health care professional online assessment and management service, for an established patient, for up to seven days, cumulative time 5- 10 minutes • G2062 - cumulative time 11-20 minutes • G2063 - cumulative time 21 or more minutes What are E-Visit codes?* * Telehealth.org Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 72. © 1994-2023 Telehealth.org, LLC All rights reserved. 72 E-Consult • Can be covered by some payers and not others. • Confirm access to these codes with all involved payers prior to using. What is an E-Consult?
- 73. © 1994-2023 Telehealth.org, LLC All rights reserved. 73 E-Consult • Known as electronic consultations or interprofessional consults, are communications between health care providers. • Providers can interact with each other by using phone, video, or a HIPAA-compliant platform that allows two-way communication and can securely share patient records. What is an E-Consult?
- 74. © 1994-2023 Telehealth.org, LLC All rights reserved. 74 E-Consult • 99446, 99447, 99448, 99449 - Verbal and written report • 99451 - Written report only What are the billing codes for E-Consults? * Telehealth.org Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 75. • Two new billing codes will be introduced so that providers can bill for virtual check-ins and remote evaluation of patient- submitted video or images. • Virtual Check-in (HCPCS Code G2012) • Store-and-Forward (HCPCS code G2010 ) • Provider and patient must be in different geographic locations • Only for patients who have an established (or existing) relationship with a physician or certain practitioners where the communication is not related to a medical visit within the previous 7 days and does not lead to a medical visit within the next 24 hours (or soonest appointment available). Virtual Check-Ins 75
- 76. • The patient must verbally consent to receive virtual check-in services. The Medicare coinsurance and deductible would generally apply to these services. • Doctors and certain practitioners may bill for these virtual check in services furnished through several communication technology modalities, such as telephone (HCPCS CPT G2012). • The practitioner may respond to the patient’s concern by telephone, audio/video, secure text messaging, email, or use of a patient portal. • * Telehealth.org Liability Disclaimer: Verify all billing codes with your billing professional(s) Virtual Check-Ins 76
- 77. © 1994-2023 Telehealth.org, LLC All rights reserved. 77 • An e-visit is when a client or patient communicates with their health care provider through an online patient portal. • A virtual check-in is billed bill for brief (5-10 minute) communications that mitigate the need for an in-person visit. What is the difference between E-Consults & Virtual Check-ins?
- 78. © 1994-2022 Telebehavioral Health Institute, LLC All rights reserved. Additional Telehealth Billing Codes E-Visit E-Consult Virtual Check-in Facility Fee • Inter- professional • Patient contact initiated by professional or staff • Billed by professional office serving as patient site • Initiated by patient through portal 78
- 79. © 1994-2023 Telehealth.org, LLC All rights reserved. 79 • Definition • Telehealth originating site facility fee • Who can collect • Originating site only • Site must bill • Not the practitioner • HCPCS code Q3014 What is a facility fee and which telemedicine CPT code can be used to collect it? * Telehealth.org Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 81. © 1994-2023 Telehealth.org, LLC All rights reserved. 81 • Visit Complexity Inherent to Certain Office/Outpatient E&Ms HCPCS G2211 • Prolonged Services HCPCS G2212 • Psychological and Neuropsychological Testing CPT 96121 What are the specific Medicare telehealth billing codes that are now permanent? * Telehealth.org Liability Disclaimer: Verify all billing codes with your billing professional(s)
- 82. Other Legal Issues of Relevance to Reimbursement
- 83. © 1994-2023 Telehealth.org, LLC All rights reserved. 83 • Practicing over state lines is illegal and subject to a variety of monetary fines and/or imprisonment for up to one year, depending on the state. • When signing the “1500 form” your signature attests to the fact that you are aware of your legal mandates and are following them all. • Insurance fraud is not taken lightly by many boards, and penalties can be steep. Why is interjurisdictional practice an issue in telehealth reimbursement?
- 84. © 1994-2023 Telehealth.org, LLC All rights reserved. 84 • However, state law and ethical codes always have required that we protect privacy • We always were obligated to protect PHI • Now that PHE is ending May 11, 2023, enforcement will return • OCR announced “discretionary enforcement” in 2020 • However, you had to inform client/patient of risks and document that informed consent process • Some issues continued to be enforced Are you required to use a HIPAA-compliant platform to get reimbursed after COVID PHE?
- 85. © 1994-2023 Telehealth.org, LLC All rights reserved. 85 • Yes - if you are properly: • Licensed • Registered Can you get reimbursed for delivering care to someone over state lines or international borders?
- 86. © 1994-2023 Telehealth.org, LLC All rights reserved. 86 What are state payers doing now? Let’s Discuss – What Can You Offer to the Group?
- 87. © 1994-2023 Telehealth.org, LLC All rights reserved. 87 • Medicare has gone on record saying that it will not “go back” • Several bills in Congress at the federal level to make Medicare reimbursement for telehealth more permanent. • See telehealth.org/blog for details. Who are the best payers to consider when planning a telehealth focus for your practice?
- 88. © 1994-2023 Telehealth.org, LLC All rights reserved. 88 • Disabled populations • Nursing homes and adult care facilities • Health-related behavioral disorders • Substance use disorders What are the best Medicare and Medicaid opportunities now?
- 89. © 1994-2023 Telehealth.org, LLC All rights reserved. 89 • Dependent on • State • Insurance company (carrier) • Diagnosis Are out-of-network providers also being covered for telehealth services?
- 90. © 1994-2023 Telehealth.org, LLC All rights reserved. 90 • Contact the company • No universal practice –the solution depends on the company • Resubmit with an explanation • Some companies will not accept repeated submissions • EHR issues How can you correct a claim if you made errors?
- 91. © 1994-2023 Telehealth.org, LLC All rights reserved. 91 • CMS Newsroom • Center for Connected Health Policy • Telehealth.org Blog & Newsletter Where to get up-do- information about telehealth reimbursement in different states so that you can grow a telehealth service into the future?
- 94. Center for Connected Health Policy - https://www.cchpca.org/
- 95. Center for Connected Health Policy - https://www.cchpca.org/
- 100. Any Questions ?
- 101. Keep in touch! ☺ Telehealth.org contact@telehealth.org 619-255-2788 Marlene M. Maheu, PhD