Billing Telehealth Updates for the South Central Region – December 2020

As we enter the new year we are seeing numerous payor telehealth policy changes, and therefore we have made several updates to the Virtual Visit Billing Guides for Arkansas, Tennessee, and Mississippi. The COVID-19 pandemic really brought into light the necessity of telehealth, and payors quickly realized their previous telehealth policies were too limited in scope, which resulted in the immediate implementation of temporary policies back in March.  As the pandemic wore on, payors saw how much traction telehealth gained with providers and patients, and therefore are beginning to revise their permanent telehealth policies to incorporate greater flexibilities.

These guides were created to save you time and intended to provide overall information and education about virtual visits, however due to the volume of information in these guides, it can be difficult for healthcare providers to decipher the best workflow for their particular situation.  We are finding in our work with organizations that there is no “one size fits all” solution.  Each unique set-up and situation must be considered in formulating the best plan for your organization. If you would like some support in a plan, please reach out to us and we would be glad to discuss how we can help.

Providing a quick high-level overview of the recent updates, all payors have extended their telehealth flexibilities to at least the end of the federal Public Health Emergency (PHE), which is currently set to end on January 20^th, 2021.  The federal PHE can only be extended 90 days at a time, and therefore may very well extend past January 20^th, 2021.  Cigna and Medicare have both rolled out significant permanent telehealth changes, with Cigna implementing a new Virtual Care Policy and Medicare implementing several additional permanent flexibilities.

Below are more detailed key updates for regional and national payors since the guides were originally published.

National Payors

Aetna

• • Extended current telehealth flexibilities until further notice.
  • Extended cost share waiver for in network behavioral and mental health visits through January 31^st, 20201.

Cigna

• • Current telehealth flexibilities expire December 31^st, 2020. Cigna’s permeant virtual care policy will go into effect January 1^st, 2021 with the following changes:
    • Providers can no longer perform any service on their fee schedule, instead Cigna released a specific allowable telehealth code set.
    • No coverage for audio only telehealth services (except telephone codes).
    • HIPAA compliant platform is now required.
  • Extend cost share waiver for diagnostic testing and office visits/telehealth visits related to assessment and administration of diagnostic testing through January 21^st, 2021.
  • Effective January 21st, 2021, cost-share and out-of-pocket costs will be the same as if they received the services in-person from that same provider.

Medicare:

• • No Changes

Medicare:

• • Implemented new Virtual Check-In Codes effective January 1^st, 2021:
    • Medicare created a new permanent HCPCS code (G2252) for 11-20 minutes of medical discussion to determine the necessity of an in-person visit. G2252 will take place of audio only allowable telehealth services once the COVID-19 PHE is over. G2252 is cross walked to CPT code 99442 for reimbursement purposes, making its reimbursement higher than the current virtual check-in code.
      • G2252: Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion
    • Medicare clarified that licensed clinical social workers, clinical psychologists, physical therapists (PTs), occupational therapists (OTs), and speech-language pathologists (SLPs) can furnish E-visits (G2061-G2063) and Virtual Check-Ins (G2250 & G2251). Medicare created two new HCPCS codes, G2250 & G2251, for virtual check-ins for these provider types.
      • G2250: Remote assessment of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment.
      • G2251: Brief communication technology-based service, e.g. virtual check-in, by a qualified health care professional who cannot report evaluation and management services, provided to an established patient, not originating from a related service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment; 5?10 minutes of clinical discussion.
    • Implemented flexibilities for direct supervision requirements through the later of the end of the calendar year in which the PHE ends or December 31, 2021 for purposes of limiting exposure to COVID-19.
      • Direct supervision can be provided using real-time, interactive audio and video technology (excluding telephone that does not also include video) through the later of the end of the calendar year in which the PHE ends or December 31, 2021.
      • The current definition of direct supervision requires the physician to be physically present in the same office and immediately available. Under the new definition, direct supervision can be met if the supervising physician is immediately available to engage via an interactive audiovisual connection. The new definition opens opportunities for telehealth and incident-to billing, as CMS has specifically clarified that services that can be provided incident-to may be provided via telehealth incident-to a distant-site physician’s service and under the direct supervision of the billing practitioner via virtual presence.
    • Reduction of the frequency limitation for subsequent nursing facility care services furnished via telehealth.
      • Reduced the frequency limitation for subsequent nursing facility visits from once every 30 days to once every 14 days.
      • Frequency limitations had already been temporarily waived for the duration of the PHE, but this new rule change is permanent, effective January 1, 2021.
    • Effective January 1^st, 2021 the following codes have been added to the Medicare allowable telehealth code list.
      • Category 1 codes are available on a permanent basis as part of the covered Medicare telehealth services list. The following category 1 codes were added:
        • Group Psychotherapy (CPT code 90853)
        • Psychological and Neuropsychological Testing (CPT code 96121)
        • Domiciliary, Rest Home, or Custodial Care services, Established patients (CPT codes 99334-99335)
        • Home Visits, Established Patient (CPT codes 99347-99348)
        • Cognitive Assessment and Care Planning Services (CPT code 99483)
        • Visit Complexity Inherent to Certain Office/Outpatient Evaluation and Management (E/M) (HCPCS code G2211)
        • Prolonged Services (HCPCS code G2212)
      • Category 3 codes are available on a temporary basis as part of the Medicare telehealth services list through the end of the year in which the COVID-19 PHE ends. The following category 3 codes were added:
        • Domiciliary, Rest Home, or Custodial Care services, Established patients (CPT codes 99336-99337)
        • Home Visits, Established Patient (CPT codes 99349-99350)
        • Emergency Department Visits, Levels 1-5 (CPT codes 99281-99285)
        • Nursing facilities discharge day management (CPT codes 99315-99316)
        • Psychological and Neuropsychological Testing (CPT codes 96130-96133; CPT codes 96136-96139)
        • Therapy Services, Physical and Occupational Therapy, All levels (CPT codes 97161-97168; CPT codes 97110, 97112, 97116, 97535, 97750, 97755, 97760, 97761, 92521-92524, 92507)
        • Hospital discharge day management (CPT codes 99238-99239)
        • Inpatient Neonatal and Pediatric Critical Care, Subsequent (CPT codes 99469, 99472, 99476)
        • Continuing Neonatal Intensive Care Services (CPT codes 99478-99480)
        • Critical Care Services (CPT codes 99291-99292)
        • End-Stage Renal Disease Monthly Capitation Payment codes (CPT codes 90952, 90953, 90956, 90959, 90962)
        • Subsequent Observation and Observation Discharge Day Management (CPT codes 99217; CPT codes 99224-99226)

United Health Care:

• • No Changes

Regional Payors

ARKANSAS

BCBS of AR:

• • No changes

Arkansas Medicaid:

• • No changes

MISSISSIPPI

BCBS of MS:

• • Extended current telehealth flexibilities until further notice.

Mississippi Medicaid:

• • Corrected HCPCS code for Miss-Psychosocial Rehabilitation from H2030 to H2017 and corrected HCPCS for Community Support Services (management of the individual) from H0036 to H2015.

TENNESSEE

BCBS of TN:

• • No Changes

Tennessee Medicaid & MCOs:

• • All Medicaid Managed Care Organizations (Amerigroup, Bluecare, and UHC Community Plan) have extended their current telehealth flexibilities and cost share waiver for COVID-19 related telehealth visits until March 31^st, 2021.

Call us to talk more about how the South Central Telehealth Resource Center can support your organization’s telehealth program. Call 1.888.664.3450 or email us at info@learntelehealth.org.

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About the author(s)

Our guest contributor is Hayley Prosser, Director of Revenue Cycle Services, ruralMED Revenue Cycle Resources. Ms. Prosser, along with Ms. Shelly Cassidy, Vice President of Revenue Cycle Services, are trusted advisors to the SCTRC and our service region, and have developed the three state-focused Virtual Visit Billing Guides and webinars now available in the “Regional Resources” section of LearnTelehealth.org.