New CMS rules and waivers expanding the use of telemedicine in response to the COVID-19 pandemic have left providers with questions about coding and billing.
In a column for Medscape.com, medical coding and compliance expert Betsy Nicoletti, MS, noted how to choose the correct level of service for a primary care telemedicine visit. She wrote that, according to new, emergency CMS rules for billing evaluation and management (E/M) services performed via telemedicine, “a practitioner could use total time or medical decision-making alone to select the level of E/M services.” If a provider bases the selection on time, counseling no longer has to comprise the majority of the appointment.
Nicoletti also explained the difference between HCPCS code G2012 and CPT code 99441 in response to a question from an OB-GYN office. Code G2012, she explained, is for a 5–10 minute phone or video visit for E/M services rendered to an established patient. These services cannot be related to E/M services provided during the previous seven days and cannot lead to an E/M service within the next 24 hours. Most insurers aren’t required to use or accept G2012.
Code 99441 carries the same stipulations as G2012, but is only for phone-based E/M services. In March, CMS updated its rules so that 99441 is now an active code rather than a non-covered code and is not considered a telemedicine code, according to Nicoletti.