Clinicians are increasingly utilizing technology in to facilitate social distancing in response to the COVID-19 Public Health Emergency (PHE). Implementing new flexibilities authorized by Congress, the Centers for Medicare and Medicaid Services (CMS) will now cover and pay for Medicare Telehealth services provided to beneficiaries regardless of location. New flexibilities also apply to telephone-only visits, virtual check-ins, and e-visits. Many private insurers are allowing similar or greater flexibility, such as provision of traditional evaluation and management (E/M) services by audio-only over the telephone.

Service	Description	CPT Codes	Provider Relationship for Fee For Service Medicare Beneficiaries
Telehealth Visits	A visit with a clinician utilizing an interactive telecommunications system (audio and video) between a clinician and a patient.	Medicare Telehealth services including, but not limited to: office visits, outpatient visits, inpatient visits, Ed visits, critical care, and nursing home visits.	Medicare PHE flexibility allows these services to be provided to both new and established patients.
Telephone Visits	A visit with a clinician utilizing telephone (audio-only) between a clinician and a patient.	99441-99443 98966-98968	Medicare PHE flexibility allows these services to be provided to both new and established patients.
Virtual Check-Ins	A brief (5-10 minutes) check in with your clinician via telephone or other telecommunications device to decide whether an office visit or other service is needed.	G2012	Medicare PHE flexibility allows these services to be provided to both new and established patients.
	A remote evaluation of recorded video and/or images submitted by an established patient.	G2010
E-Visits	A communication between a patient and their provider through an online patient portal.	99421-99423 G2061-G2063	Medicare PHE flexibility allows these services to be provided to both new and established patients.
Remote Physiologic Monitoring	Collection and/or management based on physiologic data. During PHE can be provided for both acute and chronic conditions and can now be provided for patients with only one disease.	99091, 99457, 99458, 99473, 99474	Medicare PHE flexibility allows these services to be provided to both new and established patients.

Telehealth Visit Guidance

• Medicare will consider these visits the same as in-person visits and will be paid at the same rate as regular, in-person visits. Some, but not all, payers have adopted Medicare's policy.
• Telehealth services are generally billed as if the service has been furnished in-person.
• Medicare instructs clinicians who bill Medicare Telehealth services to report the place of service (POS) code that would have been reported were the service furnished in person, such as 11 for the physician office setting. Apply CPT telehealth modifier 95 to claim lines that describe services furnished via Medicare Telehealth.
• Frequency limitations on subsequent inpatient visits (every 3 days), subsequent skilled nursing facility visits (every 30 days), and critical care consultations (once daily) have been eliminated during the PHE.
• CMS is revising policy to specific that the office/outpatient E/M level selection for these services when furnished via telehealth can be based on medical decision making (MDM) or time, with time defined as all the time associated with the E/M on the day of the encounter. Practitioners must document E/M visits as necessary to ensure quality and continuity of care. Requirements regarding documentation of history and/or physical exam in the medical record are waived. The current definition of MDM will apply.
• Private payers may still instruct the claim should reflect designated POS code 02 to indicate the billed service was furnished as a professional telehealth service from a distant site. Either modifier GT or modifier 95 may be required. Review specific payer policies for more information.

E-Visit Guidance
Individual services need to be initiated by the patient; practitioners may educate beneficiaries on availability of the service prior to patient education.

Health Insurance Portability and Accountability Act (HIPAA) Guidance
The HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency.

Additional Resources

• AMA Special COVID-19 Coding Advice
• CMS YouTube Virtual Services
• Comprehensive List of COVID-19 Response Waivers and Flexibilities
• March 30 COVID-19 Regulatory Revisions Interim-Final Rule
• ICD-10 Guidelines for COVID-19

Keywords: ACC Advocacy, Public Health, Coronavirus, Telemedicine, Emergency Medical Service Communication Systems, Centers for Disease Control and Prevention, U.S., World Health Organization, Cardiology

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