Latest telemedicine reimbursement guidelines from CMS

Understand the latest telemedicine reimbursement guidelines from CMS. See where you can provide telehealth services, who can provide it.

Categorized as Operations Tagged

CMS updated their telehealth services guidelines recently. The document can be found here.

The crux of it is that while initial guidelines were to use place of service for billing as 02 in your EMR. Now, that has been changed to 11 — that’s the same as “face to face” or in person billing place of service. So, you do not really have to do anything extra other than to add a visit type in your EMR of “TELEVISIT”.

CMS was going to make some E/M codes effective from 2021 — this included usage of E/M codes and billing them as Medical Decision Making (MDM) or Time.

Now, CMS is allowing you to choose E/M levels based on MDM or Time.

What you no longer need to document

More importantly — you do NOT need to document history and / or physical exam in the medical record if you are going to use a synchronous audio-visual telehealth visit (i.e. a video call).

Typically, you needed to record a place of service as the provider’s home or “originating site” — but due to COVID-19, CMS is no longer requiring you to do so. You can just use the practice address and CMS, for this Public Health Emergency (PHE) is going to disregard all discrepancies.

For COVID-19 purposes, CMS is also covering Telephone E/Ms (CPT 99441–99443) — this is both for new and established patients.

Store and Forward (G2010) and Virtual Check-in (G2012) — now you can use it for BOTH new and established patients. Before this, you could only use it for established patients.

The list has been updated here.

While the list of providers that are eligible to deliver telehealth services has been updated, note that FQHCs and RHCs are added only during the emergency period.

The current list of eligible providers include Physicians, Nurse practitioners, Physician assistants, Nurse-midwives. Clinical nurse specialists, Certified registered nurse anesthetists, Clinical psychologists (CP), Clinical social workers (CSWs), Registered dietitians or nutrition professionals.

Please note that CPs and CSWs cannot bill or get paid for Current Procedural Terminology (CPT) codes 90792, 90833, 90836, and 90838.

Where can you deliver telehealth services?

Before COVID outbreak, you needed to have a valid license in the state where you the patients resided (ie. you could not cross state borders).

However, just for the time being (for COVID), this particular restriction had been removed. You could provide telehealth services in the state where an emergency is happening (e.g. NYS as of writing). 

However, an interesting point to note is that the state requirements will still apply.

Hopefully this allows you to create your own practice’s telehealth strategy. Let’s look at some pros and cons of telemedicine.