CMS Pays for Communication Technology-based Services, Effective 2019
Given the recent ubiquitous nature of synchronous audio and video applications available for download and the increased use of patient-facing health portals, the Center for Medicare & Medicaid Services (CMS) has determined that a broad range of services can be provided by healthcare professionals via communication technology.
Remote Evaluation of Pre-Recorded Patient Information
Medicare will reimburse for services when a physician uses recorded video and/or images captured by a patient to evaluate the patient’s current condition. These services involve “store-and-forward” communication technology that provides for the “asynchronous transmission of health care information,” as described in the Social Security Act (the Act) §1834(m).
The 2019 CMS Medicare Physician Fee Schedule (MPFS) announced the creation of HCPCS code G2010 to report and pay for services provided by qualified healthcare professionals (QHPs) for remote professional evaluation or review of patient-transmitted information conducted via pre-recorded store-and -forward video or image obtained using asynchronous technology in an effort to determine whether an office visit or other service is warranted.
This service is billable when a physician or other QHP reviews an established patient’s submitted information via pre-recorded store-and-forward video or image technology asynchronously. This service(s) involves reviewing pre-recorded patient-generated still or video images and are not a substitute for an in-person visit.
As this type of encounter is provided asynchronously, patient follow-up is required and can be provided via phone call, audio/video communication, secure text messaging, email, or via patient portal communication. The encounter must be recorded in the patient’s medical record in a manner compliant with the Health Insurance Portability and Accountability Act (HIPAA) of 1996 and other relevant laws.
This is a stand-alone service, which can be separately billed, only if there is no related E/M office visit occurring within 7 days prior or 24 hours after the remote service
Beneficiary consent is required prior to providing a remote service, which can be obtained either in verbal or written fashion, including electronic confirmation that must be noted in the medical record for each billed store-and-forward service.
Because this service is not considered a Medicare telehealth service, it is not subject to geographic and other restrictions of telehealth services under §1834(m) of the Act.
G2010: Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment).
The following rules and guidelines must be adhered to when reporting remote service encounters:
| Encounter | Impact on remote service encounter | Resolution | Recommendation |
|---|---|---|---|
| If the review of the patient-submitted image and/or video (store-and-forward) results in an in-person evaluation and management (E/M) office visit with the same physician or QHP. | The remote service (store-and-forward) will be considered bundled into that office visit. | Store-and-forward encounter cannot be billed separately. | |
| If the remote service (store-and-forward) originates from a related E/M service provided within the previous 7 days by the same physician or QHP. | The store-and-forward encounter is considered bundled into that previous E/M service. | Store-and-forward encounter cannot be billed separately. | |
| In instances in which the quality of the pre-recorded information submitted by a patient is insufficient for the clinician to assess whether an office visit or other medical service is warranted. | The clinician could not fully furnish a remote (store-and-forward) evaluation service. | Store-and-forward encounter cannot be billed for the service. | In this circumstance, the practitioner should attempt other methods of communication with the patient to either obtain enough images to enable a remote evaluation service or suggest other appropriate alternatives. |
Coding example
A 72-year old established patient notices multiple lesions on her chest in a linear and vertical pattern. The lesions have been present for a few weeks. She sends a digital image of the lesions to her qualified provider and states that the lesions have increased in size over time and are unpleasant to look at. Every so often, they get caught in her necklace. She mentions that they started off with a light tan color, but now look like they have become dark brown. She thinks they are increasing in number.
The dermatologist/QHP obtains consent from the patient to provide the remote service. This consent is noted in the patient record.
The dermatologist or QHP reviews the image and sends an electronic message advising the patient that the lesions are seborrheic keratoses. The patient is advised to watch the site and schedule an appointment in the office for an in-person follow-up should anything change.
Because this is the first time the patient presents for this problem, the dermatologist or QHP is able to separately report this encounter as a stand-alone communication technology encounter.
After the dermatologist or QHP reviews images, the diagnosis is documented in the medical record and a claim with HCPCS codeG2010 is submitted to Medicare.
Medicare Coverage of Brief Check-in Services Using Communication Technology
As of January 1, 2019, practitioners can bill Medicare for brief check-in services provided to evaluate whether an office visit or other service is warranted, that are conducted using communication technology. A brief communication technology-based service (i.e., virtual check-in) is defined as a service (5-10 minutes of medical discussion) provided by a physician or other QHP, who can report evaluation and management (E/M) services, provided to an established patient that does not originate from a related E/M service provided within the previous 7 days or lead to an E/M service or procedure within the next 24 hours or soonest-available appointment.
If the check-in service does not lead to an office visit, then there is no office visit to bundle with the check-in service. The service would be billable as a virtual check-in in which the physician or other QHP has a brief nonface-to-face check-in with a patient via communication technology to assess whether the patient’s condition warrants an office visit.
The encounter requires audio-only real-time telephone interaction in addition to synchronous, two-way audio interactions that are enhanced with video or other kinds of data transmission.
Telephone calls that involve only clinical staff cannot be billed using HCPCS code G2012 because the code explicitly describes (and requires) direct interaction between the patient and the billing practitioner.
In order to provide and report the brief check-in service furnished using communication technology, there has to be an established relationship between the patient and the provider, who has basic knowledge of the patient’s medical condition and needs, and requires a verbal consent that is noted in the medical record for each billed service.
G2012: Brief communication technology-based service, e.g., virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion. The following rules and guidelines must be adhered to when reporting remote service encounters:
| Encounter | Impact on technology-based communication service encounter | Resolution |
|---|---|---|
When the brief communication technology–based service originates from a related E/M service provided within the previous 7 days by the same physician or other QHP | Technology-based service would be considered bundled into that previous E/M service | Encounter cannot be reported separately. |
| When the brief communication technology–based service leads to an E/M service with the same physician or other QHP within 24 hours or soonest available appointment. | Technology-based service would be considered bundled into that previous E/M service | Encounter cannot be reported separately. |
Coding example
A 77-year old farmer, recently applied insecticide to his crop. The next day, he woke up scratching his arms and chest, but did not think much of it. After a few days, he realized the condition was not improving and sets up a virtual appointment with his dermatologist.
Via real-time, synchronous video communication, he shows his itchy, red blistered chest and arms to his dermatologist. The dermatologist diagnosed irritant contact dermatitis due to exposure to insecticide.
The dermatologist advises the patient that he will electronically prescribe an ointment and requests a follow-up appointment in the office after 10 days.
The dermatologist documents this encounter as a stand-alone synchronous (real-time) virtual check-in service with the patient in the medical record and submits code G2012 to Medicare.
Like any physician service, the service must be medically reasonable and necessary in order to qualify for payment by Medicare. Medicare cost-sharing rules apply (80/20 rule) in which Medicare pays 80 percent and the patient responsibility or co-insurer responsibility is 20 percent.
There is no frequency limit on the use of HCPCS code G2012 by the same practitioner with the same patient. The code should be used appropriately for circumstances when a patient needs a brief nonface-to-face check-in to assess whether an office visit is necessary.
Interprofessional Telephone/Internet/Electronic Consultation Services
There are two new codes with separate payment for interprofessional telephone/Internet consultations between a treating physician and consulting physician.
99451: Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician, including a written report to the patient’s treating/requesting physician or other qualified healthcare professional, 5 minutes or more of medical consultative time.
99452: Interprofessional telephone/Internet/electronic health record referral service(s) provided by a treating requesting physician or other qualified health care professional, 30 minutes.
Rules to bill by
Consult:
Service must be initiated by a physician or other QHP
Treating physician requests an opinion and/or advice from consulting physician
New or established patient consult
Established patient: new problem or exacerbation of an existing problem
Time component:
Time spent must be majority consultative in nature—verbal/Internet discussion
Can be cumulative over multiple contacts via telephone/Internet/electronic health record (EHR)
Limitations:
Patient was seen by consultant within the last 14 days
The interprofessional consultation leads to transfer of care within the next 14 days or next available appointment date
