Coding Q&A By Stephanie L. Dybul, MBA, RT


Coding telehealth services and virtual visits


What are the CPT codes for a virtual video telehealth visit? A virtual video visit is reported with the same CPT codes that you would use for in-person visits (99201–99205 new patient visit; 99211–99215 established patient visit; or 99241–99245 consultation visit [not recognized by CMS, see G-codes]). The service should be reported with a -95 modifier (confirm your local payer rules). There must be a synchronous two-way audio and visual component to the visit in order to report using these standard codes. Additionally, it should be noted that the place of service (POS) listed on the claim should match wherever the intended POS would have been in normal circumstances. For example, if you typically perform your clinic visit in an on-campus, OP hospital setting, report POS 22 for facility or POS 11 for nonfacility/office setting. Currently, telehealth services are reimbursed under the CMS Physician Fee Schedule at the same amount as in-person services.


Are there any special documentation requirements for virtual video visit? You should document all of the same elements that you would normally, with consideration of what is possible for you to achieve via the video connection. Typical elements of past medical history can be taken, limited examinations can be performed and documentation of your medical decision making (MDM) or time spent counseling should be clearly stated. However, CMS is removing requirements


regarding documentation of history and/ or physical exam in the medical record. Additionally, it should be noted that, on an interim basis, CMS is revising their policy to specify that the outpatient E&M level selection for these services when furnished via telehealth can be based on MDM or time, with time defined as all of the time associated with the E&M on the day of the encounter. It remains CMS’ expectation that providers will document E&M visits as necessary to ensure quality and continuity of care. These policy changes only apply to office/outpatient visits furnished via Medicare telehealth, and only during the Public Health Emergency (PHE) for the COVID-19 pandemic. It is strongly recommended to work with your coding/compliance team to ensure that language required by all payers is included in the documentation to ensure timely payment.


Can I bill an E&M service for telephone calls to patients? Yes, there are CPT codes to support telephone E&M service, with the understanding that two-way audio- visual technology may not be available. Briefly, they are described as follows (see CPT® for full descriptors):


99441: Telephone E&M, for an established patient, 5–10 minutes


99442: Telephone E&M, for an established patient, 11–20 minutes


99443: Telephone E&M, for an established patient, over 21 minutes


These codes are only reportable when providing E&M services to an established patient and cannot be reported within 7 days of a previously provided E&M service or within 24 hours of a procedure. During the PHE, CMS has established that these codes can be used for new patients.


Is responding to a patient’s electronic message billable? Yes, CPT codes 99421–99423 can be used when a provider responds to a


26 IRQ | SUMMER 2020


patient generated electronic inquiry. These E&M services do not use interactive audio or visual. As with other non-face- to-face E&M services, the codes are time based and are cumulative over a 7-day period; which begins when the provider reviews the initial patient generated inquiry. The time includes review of patient’s medical records, the time to perform medical decision-making, develop a plan and place orders, as well as the time for communication back to the patient. Permanent documentation should support the time and effort taken, including documentation of the time in minutes spent performing these activities. The codes may not be used for work done by clinical staff and should not be billed if/when other E&M services are provided within the past 7 days. During the PHE, these codes can be used for new patients or established patients.


99421: Online digital E&M service, for an established patient, for up to 7 days cumulative time during the 7 days; 5–10 minutes


99422: Online digital E&M service, for an established patient, for up to 7 days cumulative time during the 7 days; 11–20 minutes


99423: Online digital E&M service, for an established patient, for up to 7 days cumulative time during the 7 days; 21 or more minutes.


*The content and guidance described in this article was current at the time it was written. Due to the nature of the recent PHE, payment policy is likely to change rapidly and may vary geographically. Members should continue to follow and consult local/national payer guidelines for most up-to-date guidance. Also refer to SIR’s telehealth information within the COVID-19 Toolkit: bit.ly/2YcQz4u.


SIR is providing this billing and coding guide for educational and information purposes only. It is not intended to provide legal, medical or any other kind of advice. The guide is meant to be an adjunct to the American Medical Association’s (AMA’s) Current Procedural Terminology (2019/CPT®). It is not comprehensive and does not replace CPT. Our intent is to assist physicians, business managers and coders. Therefore, a precise knowledge of the definitions of the CPT descriptors and the appropriate services associated with each code is mandatory for proper coding of physician service.


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