Test Your Knowledge: Coding for Telehealth Performed During the COVID-19 PHE

Information regarding coding, coverage, and payment is provided as a service to our readers. Every effort has been made to ensure accuracy. However, HMP and the author do not represent, guarantee, or warranty that coding, coverage, and payment information is error-free and/or that payment will be received.

The COVID-19 public health emergency (PHE) has caused wound/ulcer management professionals and providers to adjust their business models quickly to meet the needs of their patients. Because older patients and patients with diabetes, heart disease, renal disease, etc., were advised to stay at home during the COVID-19 PHE, many of them canceled their wound/ulcer assessment appointments, which began to have unintended consequences such as new infections, emergency department visits, hospitalizations, and even amputations. The wound/ulcer management professionals and providers were desperate to find ways to regularly assess their patients’ wounds/ulcers.

Therefore, wound/ulcer management professionals, as well as many other physicians and qualified health care professionals (QHPs) throughout the country, requested that the Centers for Medicare and Medicaid Services (CMS) relax the telehealth regulations and allow the physicians/QHPs to provide telehealth services to patients in their homes. In response to these many requests, the CMS released two Interim Final Rules, one on March 30, 2020 and the other on April 30. Even though you have probably read those rules and their waivers multiple times, following are a few of the telehealth refinements that greatly assist physicians/QHPs to conduct wound/ulcer assessments via telehealth:

• Added approximately 100 codes to the list of covered Medicare telehealth services. Now more than 200 services can be furnished via two-way audio and video technology. In addition, the Office of Civil Rights (OCR) temporarily allows good faith-use of non-public-facing applications, such as Apple FaceTime, Facebook Messenger Video Chat, Google Hangouts Video, Zoom, and Skype.  

• Allowed and increased payment rates for audio only evaluation and management services (99441–99443) to temporarily serve as telehealth services

• Expanded the types of health care professionals who can provide telehealth services: the expansion included therapists

• Eliminated the telehealth frequency limitations for subsequent inpatient visits, subsequent skilled nursing facility visits, and critical care consults

• Allowed the annual beneficiary consent to be obtained at the time the telehealth service is furnished

• Allowed telehealth for patients who did not have a prior physician-patient relationship

• Provided flexibility for health care providers to reduce or waive cost-sharing for telehealth visits

• Reimbursed federally qualified health clinics and rural health clinics for providing telehealth services

• Allowed clinicians to practice across state lines in person and via telehealth: clinicians must still follow applicable state laws

• Allowed physicians and other practitioners to render telehealth services from their home without reporting their home address on their Medicare enrollment while continuing to bill Medicare from their currently enrolled location

Keep in mind that the relaxed telehealth policies are time-limited to the PHE. Currently the PHE is set to expire at the end of July 2020. However, it can be renewed in 90-day increments.  

At this stage of the PHE, numerous wound/ulcer management professionals and providers have reported, to this author, that they have provided many telehealth services for a wide variety of patients in their homes and other sites of care. Some reported that they simply submitted claims with the codes they typically use, which can dangerously lead to denials and/or false claims. Many others reported that they have not submitted their claims to Medicare because the regulations have been rapidly changing. They are not sure what place of service, what service code, what modifier, and what condition code correctly represents the telehealth work they performed for patients in various sites of care during the COVID-19 PHE.

Therefore, this author has prepared 10 scenarios that professionals can use to test their COVID-19 telehealth coding knowledge before they submit their claims to Medicare. CAUTION: The information provided in Tables 1 and 2 is based on the COVID-19 regulations and waivers as of May 18, 2020. Wound/ulcer management professionals should monitor the ever-changing COVID-19 regulations that may occur after May 18 and throughout the PHE.   

To test your coding knowledge for telehealth performed during the COVID-19 PHE, read the scenarios in Table 1 and complete the place of service, the service code(s), and the modifier(s) that should be reported on the Medicare claim for each scenario. Then turn to Table 2 on page 7 where you will find the correct coding answers, as well as the explanations for the answers.

Kathleen D. Schaum is a founding member of the Today’s Wound Clinic editorial advisory board and oversees a consulting business. She can be reached for consultation and questions by emailing kathleendschaum@bellsouth.net.

For related content, see Kathleen D. Schaum’s webinar, “COVID-19 Reimbursement Depends on What Was Performed: Telehealth or Communication Technology-Based Service?” at https://tinyurl.com/ycfhk2p5.