Telehealth and Communication Technology-Based Services (CTBS) A Guide for Providers During the COVD-19 Public Health Emergency (PHE) Telehealth Telehealth is a service that allows providers to consult with their patients through audio/video communication technology. *Risk adjustment: Diagnoses from telehealth services will be accepted for hierarchal condition category (HCC) capture for both Medicare Advantage (MA) and Qualified Health Plan (QHP) patients under the Centers for Medicare and Medicaid Services (CMS)-HCC and the U.S. Department of Health and Human Services (HHS)-HCC risk-adjustment models. Telehealth visits using real-time audio/video technology will be considered a valid face-to-face encounter. Services are still subject to risk-adjustment requirements, such as provider type and diagnostic value. Communication Methods Synchronous real-time interactive communication through audio and video is a valid method. Section 1135(b) waiver of the Social Security Act allows the use of phones that have audio or video capabilities (such as FaceTime, Skype, etc.) for telehealth serviced during the COVID-19 PHE. Qualified Providers Qualified providers include physicians, nurse practitioners, physician assistants and certified nurse midwives. Other qualified nonphysician healthcare professionals, such as certified nurse anesthetists, licensed clinical social worker (LCSW), clinical psychologists, registered dietitians or nutrition professionals may provide covered telehealth services within their scope of practice – this includes Federally Qualified Health Centers(FQHCs)/ Rural Health Centers (RHCs). Patient Qualifications New and established patients may receive telehealth services from any healthcare facility or in their home, regardless of geographic location. Covered Services Common and expanded covered services during the PHE include: • Outpatient evaluation and management services (99201-99215) • Medicare annual wellness visits (G0438-G0439) • Preventive exams* (99381-99387; 99391-99397) *Preventive exams are only acceptable for risk adjustment HCC capture under the HHS-HCC model for QHP plans. • Home visits (99341-99345; 99347-99350) • Psychological and neuropsychological testing (96130-96133; 96136-96139) • Therapy services, physical and occupational therapy (97161-97168; 97110, 97112, 97116, 97535, 97750, 97755, 97760, 97761, 92521-92524, 92507) • Emergency department or initial inpatient consultations (G0425-G0427) • Follow-up inpatient hospital or skilled nursing facility consultations (G0406-G0408) CMS has published a full list of services that may be provided through telehealth at: cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes Billing Requirements • Bill services with either place of service (POS) 02 or with the place of service that would have been used if the services had been provided in person and attach modifier 95 to the respective CPT/HCPC code. • FQHCs/RHCs: For distant site services provided from January 27 to June 30, 2020, attach modifier 95 to the claim. For distant site services provided from July 1, 2020, through the end of the COVID-19 PHE, use HCPC G2025 to identify telehealth services. • Use Modifier GT for CAH Method II. • Use Modifer G0 for services for the diagnosis and treatment of an acute stroke. • When a patient receives telehealth services while in a healthcare facility, the facility is eligible to bill for the originating site facility fee, using HCPCS code Q3014. • Use time or MDM to determine the level for E/M selection. Typical times associated with each E/M can be found at: cms.gov/Medicare/Medicare-Fee-for-Service- Payment/PhysicianFeeSched/PFS-Federal-Regulation-Notices-Items/CMS-1715-F CTBS: Telephone Assessment and Management Services Telephone assessment and management services would take place only when telehealth services through video/audio are not available. *Risk adjustment: Diagnoses from telephone assessment and management services are not considered face-to-face and will not be accepted for HCC capture for MA or QHP patients under the CMS-HCC and HHS-HCC risk-adjustment models. Communication Methods Synchronous communication by telephone is a valid method. Patient Qualifications New and established patients, regardless of geographic location, are considered qualified patients. Covered Services For qualified healthcare professionals who can report evaluation and management services: • 99441: Telephone assessment and management services (5-10 minutes). • 99442: Telephone assessment and management services (11-20 minutes). • 99443: Telephone assessment and management services (21-30 minutes). Covered Services For qualified nonphysician healthcare professional, such as physical therapists, occupational therapists, speech-language pathologists and clinical psychologists, etc.: • 98966: Telephone assessment and management services (5-10 minutes). • 98967: Telephone assessment and management services (11-20 minutes). • 98968: Telephone assessment and management services (21-30 minutes). Billing Requirements • Occupational and physical therapists and speech-language pathologists must use therapy modifiers GO, GP or GN on CPT codes 98966-98968. Special Considerations and Limitations: Telephone assessment and management services should only be used when telehealth services through video and audio are not available. CTBS: Virtual Check-Ins Virtual check-ins are brief communications between the patient and provider (5-10 minutes of medical discussion), including the evaluation of videos or images submitted by the patient. *Risk adjustment: Diagnoses from virtual check-ins are not considered face-to-face and will not be accepted for HCC capture for MA and QHP patients under the CMS-HCC and HHS-HCC risk-adjustment models. Communication Methods Synchronous and/or asynchronous communication through telephone, audio/visual, secure text messaging, email or patient portal are considered valid communication methods. Qualified Providers Qualified healthcare professionals are those who can report evaluation and management services. Virtual check-ins have also been expanded for use by other practitioners, such as physical therapists, occupational therapists, speech-language pathologists, LCSWs and clinical psychologists (includes FQHCs/RHCs). Patient Qualifications New and established patients, regardless of geographic location, are considered qualified patients. Covered Services • G2012: Brief technology-based services with 5-10 minutes of medical discussion • G2010: Remote evaluation and interpretation of recorded video and/or images submitted by patient. • G0071: For FQHCs/RHCs use only. Services for G2012 and G2010 provided by an FQHC/RHC must be reported using the FQHCs/RHCs HCPCS code. Considerations and Limitations • Services must be initiated by the patient. • Services cannot originate from a related E/M service within the previous seven days or lead to an E/M services/procedure within the next 24 hours. CTBS: E-Visits E-visits are communications that occur between the provider and patient through an online patient portal over the course of up to seven days. *Risk adjustment: Only diagnoses for QHP patients from e-visits will be accepted for HCC capture under the HHS-HCC risk-adjustment model. Services are still subject to risk-adjustment requirements, such as provider type and diagnostic value. For MA patients, diagnoses from e-visits are not considered face-to-face and will not be accepted for HCC capture for MA patients under the CMS-HCC risk-adjustment model. Communication Methods Asynchronous communication through an online patient portal is a valid communication method. Patient Qualifications New and established patients, regardless of geographic location, are considered qualified patients. Covered Services For qualified healthcare professionals who can report evaluation and management services: • 99421: Online digital E/M service, for up to seven days, cumulative time during the seven days (5-10 minutes). • 99422: Online digital E/M service, for up to seven days, cumulative time during the seven days (11-20 minutes). • 99423: Online digital E/M service, for up to seven days, cumulative time during the seven days (more than 21 minutes). • G0071: For FQHCs/RHCs use only. Services for 99421-99423 provided by an FQHC/RHC must be reported using this FQHCs/RHCs HCPCS code. Covered Services For qualified nonphysician healthcare professionals, such as physical therapists, occupational therapists, speech-language pathologists and clinical psychologists, etc: • G2061: Online assessment and management, for up to seven days (5-10 minutes). • G2062: Online assessment and management, for up to seven days (11-21 minutes). • G2063: Online assessment and management, for up to seven days (more than 21 minutes). Billing Requirements • Occupational and physical therapists and speech-language pathologists need to attach therapy modifiers GO, GP or GN on CPT codes G2061-G2063. Considerations and Limitations • Services cannot originate from a related E/M service within the previous seven days or lead to an E/M services/procedure within the next 24 hours. • Services must be initiated by the patient. FAQs Q: Are telehealth and CTBS services limited to patients with COVID-19 or suspected to have COVID- 19? A: No, services are not limited to patients with or suspected to have COVID-19. As with all other services, telehealth and CTBS services must be reasonable and medically necessary. Q: How will telehealth and CTBS services be covered? A: All telehealth and CTBS services