“There were different payer guidelines, [so] we needed to make sure our membership had as much information as they possibly could for their staff to be able to continue to have a fairly good workflow with patients, because the patients are still coming in,” Ms. Chung said.
Part of updating coding and billing practices is being aware of the two new ICD-10 codes related to COVID-19:
- U07.1—“COVID-19, virus identified” is assigned to a disease diagnosis of COVID-19 confirmed by laboratory testing.
- U07.2—“COVID-19, virus not identified” is assigned to a clinical or epidemiological diagnosis of COVID-19 where laboratory confirmation is inconclusive or not available.
In addition to the new ICD-10 codes, there are new requirements related to billing for telemedicine visits, which depend on the type of visit and the insurance carrier’s policies. Many of these policies are in line with the CMS, but there are differences, Ms. Chung said.
“With all the telehealth rules and different carriers having different rules, you must verify the patient’s insurance carrier to understand their telehealth visit guidelines,” says Melesia Tillman, CPC, CPC-I, CRHC, CHA, ACR reimbursement specialist. To make it more challenging, the rules keep changing. To help, ACR has provided a Commercial Payer Temporary Telehealth Policies[KR10] document, which links out to third-party payer telemedicine policies, lists effective dates, and provides other details for various carriers.9
As an example of rule changes, Medicare originally required that practices use “02” for the place-of-service code, denoting a telehealth visit, but then switched it to “11,” which is an in-office code. This was done so the reimbursement amounts would be more accurate, Ms. Tillman explained. The CMS also added “95” as a modifier (to be entered on the claims line for services furnished), which identifies telemedicine as opposed to an in-person evaluation and management (E/M) visit.
Another update to billing and coding practices is that Medicare is allowing the use of its revised 2021 E/M guidelines. The new guidelines allow physicians to choose whether their documentation is based on medical decision making or on total time, as discussed in a recent article from the American Medical Association.10 Total time used for billing includes physician time, as well as other providers’ time (such as nurse practitioners or physician assistants), but not ancillary staff time, Ms. Tillman explains.
Further, billed time can be spent on the patient visit and related activities, such as charting, calling in prescriptions and reviewing laboratory results, “so long as you do it on the same date as the actual telehealth visit,” Ms. Tillman says.