Billing and Coding for Telehealth Services in Light of COVID-19

March 18, 2020

As the COVID-19 situation escalates, many of our clients have been asking us about performing virtual visits for patients and whether insurance will reimburse for virtual visits. This post will provide some updates on the current telehealth billing details and requirements.

In recent years, many commercial insurances have started covering telehealth services, or virtual patient visits. However, Medicare has restricted coverage for these visits to patients in rural areas with limited access to medical care.

On Monday, CMS announced that it would expand its coverage of telehealth services, in an effort to provide additional medical care and to help keep patients safe for the duration of the COVID-19 state of emergency.

Here are the details and requirements for performing and billing for virtual visits:

  • General Coverage: Medicare, Medicaid in most states, and large PPO insurances will all be covering virtual visits. We expect smaller insurance companies (Workers Comp, IPA’s, etc.) to follow suit, but we suggest checking with them beforehand to find out if they will be covering virtual visits.
  • HIPAA: the federal government has suspended some of its stricter HIPAA requirements. Providers will be allowed to perform virtual visits from personal phones and devices and through everyday communication methods, such as FaceTime and Skype.
  • Locations: virtual visits will be covered for patients seen at home, in the hospital, and skilled nursing facilities. In addition, the previous requirement that the provider be working from a medical setting has been temporarily suspended so that providers can provide services from home.
  • Non-Physician Providers: virtual services may also be provided by non-physician providers, including NP’s and PA’s.
  • Technology Requirements: the visits must include both video and audio with two-way, real-time, interactive communication. Audio alone is insufficient.
  • Reimbursement: the reimbursement for virtual visits will be the same as in-person visits.
  • Documentation: the documentation should be the same as for an in-person visit. It is advisable to include in the note that the visit was performed virtually and which technology was used to provide the services. In addition, the note should document that the patient was made aware that the visit would be performed virtually and consented.
  • CPT Coding and Modifiers: the coding requirements vary by insurance company. We are putting together a coding guide for the larger insurance companies and will release this separately. (To our clients: please continue to submit your billing as usual with the same E/M codes and indicate that the visit was performed virtually; we sill submit the claim with the correct coding based on each insurance company’s guidelines).

We know that this is a challenging time for you and your practice. We are proud to be working with you as you work on the front-lines.



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