Panacea is providing guidance for institutional (facility) billing during this public health emergency. Hospitals will need to take additional steps to ensure coding and billing are appropriate during this time. For the most part, billing for telehealth services has not changed with exception of the information provided below.

HCPCS code Q3014 (Telehealth facility fee) describes the Medicare telehealth originating site facility fee. Hospitals will bill Medicare MAC for the separately billable, Part B, originating site facility fee. Even though many non-government payers have relaxed some of their coding and billing requirements during this emergency, and many may not recognize use of Q3014 on their commercial claims. However, you may be able to use Q3014 on Medicare and Medicaid replacement claims. Outside of commercial payer published guidance, at this time, and to minimize working around claim edits, hospitals can bill separately for this service and track any denials.

Remember HCPCS code Q3014 is a separate charge that is intended to pay for the technology in the originating site; therefore, the patient must be physically located in the hospital. Hospitals will code and bill any applicable telehealth services provided. This includes audiovisual evaluation and management services (e.g., G0463, 99201-99215) and psychotherapy services (e.g., 90832-90838). Most other codes are still not valid for facility billing (see Facility Telehealth Coding and Billing table below). It is important to also remember other information required for billing on the institutional claim:

Section 1135 and Section 1812(f) Waivers as a result of the Public Health Emergency (PHE), apply the following to claims for which Medicare payment is based on a “formal waiver” including, but not limited to, Section 1135 or Section 1812(f) of the Act:

  1. The “DR” (disaster-related) condition code for institutional billing, i.e., claims submitted using the ASC X12 837 institutional claims format or paper Form CMS-1450.
  2. The “CR” (catastrophe/disaster-related) modifier for Part B billing, both institutional and non-institutional, i.e., claims submitted using the ASC X12 837 professional claim format or paper Form CMS-1500 or, for pharmacies, in the NCPDP format.

Telehealth modifiers also need to be considered for reporting and these are appended to the separate charges for the evaluation and management or other telehealth service provided via these forms of telecommunications:

  • GQ (Via asynchronous telecommunications system)
  • GT (Via interactive audio and video telecommunication systems) during this time this may include use of Skype, FaceTime, Zoom with secure transmission.

Medicare defines “store and forward” as the asynchronous transmission of medical information to be reviewed at a later time by physician or practitioner at the distant site. A patient’s medical information may include, but not limited to, video clips, still images, x-rays, MRIs, EKGs and EEGs, laboratory results, audio clips, and text. The physician or practitioner at the distant site reviews the case without the patient being present. Store and forward substitutes for an interactive encounter with the patient present; the patient is not present in real-time.

NOTE: Asynchronous telecommunications system in single media format does not include telephone calls, images transmitted via facsimile machines and text messages without visualization of the patient (electronic mail). Photographs must be specific to the patients’ condition and adequate for rendering or confirming a diagnosis and or treatment plan. Dermatological photographs, e.g., a photograph of a skin lesion, may be considered to meet the requirement of a single media format under this instruction.

CMS was not able to address the question about new patient visits during the Stakeholder Call on March 16, 2020. We would expect to see something published at a future time. Virtual visits for established patients are billable.

LIST OF FACILITY TELEHEALTH SERVICES DURING CORONAVIRUS CY 2020
HCPCS Code Long Descriptor SI  Payment Rate Instructions for Use During Coronavirus Outbreak
G0463 Hospital outpatient clinic visit for assessment and management of a patient J2  $       115.93 For Medicare, use as applicable for audiovisual communication between a hospital provider and the patient
Q3014 Telehealth originating site facility fee A  $        26.65 Facility originating site fee, paid under the MPFS
99211 Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician or other qualified health care professional. Usually, the presenting problem(s) are minimal. Typically, 5 minutes are spent performing or supervising these services. B  Not OPPS Use as applicable for audiovisual communication between a hospital provider and the patient
99212 Office or other outpatient visit for the evaluation and management of an established patient, which requires at least 2 of these 3 key components: A problem focused history; A problem focused examination; Straightforward medical decision making. Counseling and/or coordination of care with other physicians, other qualified health care professionals, or agencies are provided consistent with the nature of the problem(s) and the patient’s and/or family’s needs. Usually, the presenting problem(s) are self limited or minor. Typically, 10 minutes are spent face-to-face with the patient and/or family. B  Not OPPS For non-governmental payers, use as applicable for audiovisual communication between a hospital provider and the patient
99213 Office or other outpatient visit for the evaluation and management of an established patient, which requires at least 2 of these 3 key components: An expanded problem focused history; An expanded problem focused examination; Medical decision making of low complexity. Counseling and coordination of care with other physicians, other qualified health care professionals, or agencies are provided consistent with the nature of the problem(s) and the patient’s and/or family’s needs. Usually, the presenting problem(s) are of low to moderate severity. Typically, 15 minutes are spent face-to-face with the patient and/or family. B  Not OPPS For non-governmental payers, use as applicable for audiovisual communication between a hospital provider and the patient
99214 Office or other outpatient visit for the evaluation and management of an established patient, which requires at least 2 of these 3 key components: A detailed history; A detailed examination; Medical decision making of moderate complexity. Counseling and/or coordination of care with other physicians, other qualified health care professionals, or agencies are provided consistent with the nature of the problem(s) and the patient’s and/or family’s needs. Usually, the presenting problem(s) are of moderate to high severity. Typically, 25 minutes are spent face-to-face with the patient and/or family. B  Not OPPS For non-governmental payers, use as applicable for audiovisual communication between a hospital provider and the patient
99215 Office or other outpatient visit for the evaluation and management of an established patient, which requires at least 2 of these 3 key components: A comprehensive history; A comprehensive examination; Medical decision making of high complexity. Counseling and/or coordination of care with other physicians, other qualified health care professionals, or agencies are provided consistent with the nature of the problem(s) and the patient’s and/or family’s needs. Usually, the presenting problem(s) are of moderate to high severity. Typically, 40 minutes are spent face-to-face with the patient and/or family. B  Not OPPS For non-governmental payers, use as applicable for audiovisual communication between a hospital provider and the patient
90791 Psychiatric diagnostic evaluation Q3  $       131.36 Use as applicable for behavioral patients seen virtually
90792 Psychiatric diagnostic evaluation with medical services Q3  $       131.36 Use as applicable for behavioral patients seen virtually
90832 Psychotherapy, 30 minutes with patient Q3  $       131.36 Use as applicable for behavioral patients seen virtually
90833 Psychotherapy, 30 minutes with patient when performed with an evaluation and management service (List separately in addition to the code for primary procedure) N  Packaged Use as applicable for behavioral patients seen virtually
90834 Psychotherapy, 45 minutes with patient Q3  $       131.36 Use as applicable for behavioral patients seen virtually
90836 Psychotherapy, 45 minutes with patient when performed with an evaluation and management service (List separately in addition to the code for primary procedure) N  Packaged Use as applicable for behavioral patients seen virtually
90837 Psychotherapy, 60 minutes with patient Q3  $       131.36 Use as applicable for behavioral patients seen virtually
90838 Psychotherapy, 60 minutes with patient when performed with an evaluation and management service (List separately in addition to the code for primary procedure) N  Packaged Use as applicable for behavioral patients seen virtually
90839 Psychotherapy for crisis; first 60 minutes Q3  $       131.36 Use as applicable for behavioral patients seen virtually
90840 Psychotherapy for crisis; each additional 30 minutes (List separately in addition to code for primary service) N  Packaged Use as applicable for behavioral patients seen virtually
90845 Psychoanalysis Q3  $       131.36 Use as applicable for behavioral patients seen virtually
T1014 Telehealth transmission, per minute, professional services bill separately For Medicaid, use as applicable for audiovisual communication between a hospital provider and the patient
LIST OF MEDICARE TELEHEALTH SERVICES CY 2020
99441 Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian 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 E1  Excluded This service is not covered for facility billing
99442 Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian 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; 11-20 minutes of medical discussion E1  Excluded This service is not covered for facility billing
99443 Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian 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; 21-30 minutes of medical discussion E1  Excluded This service is not covered for facility billing
98966 Telephone assessment and management service provided by a qualified nonphysician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion E1  Excluded This service is not covered for facility billing
98967 Telephone assessment and management service provided by a qualified nonphysician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion E1  Excluded This service is not covered for facility billing
98968 Telephone assessment and management service provided by a qualified nonphysician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 21-30 minutes of medical discussion E1  Excluded This service is not covered for facility billing
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 M Not OPPS This service is not covered for facility billing
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 M Not OPPS This service is not covered for facility billing
G0406 Follow-up inpatient consultation, limited, physicians typically spend 15 minutes communicating with the patient via telehealth B Not OPPS This service is not covered for facility billing
G0407 Follow-up inpatient consultation, intermediate, physicians typically spend 25 minutes communicating with the patient via telehealth B Not OPPS This service is not covered for facility billing
G0408 Follow-up inpatient consultation, complex, physicians typically spend 35 minutes communicating with the patient via telehealth B Not OPPS This service is not covered for facility billing
G0425 Telehealth consultation, emergency department or initial inpatient, typically 30 minutes communicating with the patient via telehealth B Not OPPS This service is not covered for facility billing
G0426 Telehealth consultation, emergency department or initial inpatient, typically 50 minutes communicating with the patient via telehealth B Not OPPS This service is not covered for facility billing
G0427 Telehealth consultation, emergency department or initial inpatient, typically 70 minutes or more communicating with the patient via telehealth B Not OPPS This service is not covered for facility billing
G0508 Telehealth consultation, critical care, initial , physicians typically spend 60 minutes communicating with the patient and providers via telehealth B Not OPPS This service is not covered for facility billing
G0509 Telehealth consultation, critical care, subsequent, physicians typically spend 50 minutes communicating with the patient and providers via telehealth B Not OPPS This service is not covered for facility billing

Resources:

Medicare Telehealth Services

Summary of Policies in the Calendar Year (CY) 2020 Medicare Physician Fee Schedule (MPFS) Final Rule, Telehealth Originating Site Facility Fee Payment Amount and Telehealth Services List, CT Modifier Reduction List, and Preventive Services List   

Medicaid Telemedicine

Emergency Medical Treatment and Labor Act (EMTALA) Requirements and Implications Related to Coronavirus Disease 2019 (COVID-19)

Revisions to the Telehealth Billing Requirements for Distant Site Services (special instructions for Critical Access Hospitals)

Coronavirus COVID-19 Stakeholder Calls