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Use these resources for clean claims.

With hundreds of codes added to the list of services covered as telehealth during the public health emergency (PHE) for the COVID-19 pandemic, the following tips should help you stay current on codes and coverage.

Tip 1: Track 鈥楾emporary鈥� Telehealth Codes

You can keep track of the most current list of covered telehealth codes, including the most recent quarterly updates, by downloading the latest file at www.cms.gov/Medicare/ Medicare-General-Information/Telehealth/Telehealth-Codes. This file not only lists the codes, but it provides additional information such as when the code was added as part of the PHE and when it may expire.

You should understand that CMS designates some codes on the list as 鈥淐ategory 3鈥� codes. According to the Medicare Physician Fee Schedule Final Rule for 2021, 鈥淐ategory 3 describes services added to the Medicare telehealth list during the [PHE] that will remain on the list through the calendar year in which the PHE ends.鈥� You鈥檒l see the phrase 鈥淎vailable up through the year in which the PHE ends鈥� in the status column of Category 3 codes on the list. You should distinguish that from codes in which the status column states, 鈥淭emporary Addition for the PHE for the COVID-19 Pandemic,鈥� because the end dates may be different.

CPT^庐 is different: You鈥檒l see a 5 point star symbol in CPT^庐 2021 that designates codes you can bill as telehealth, according to Melanie Witt, RN, MA, an independent coding expert based in Guadalupita, New Mexico. Appendix P will also list telemedicine codes. But those codes are only the permanent telehealth services, and you won鈥檛 find the temporary telehealth codes marked with a star or on the Appendix P list in CPT^庐 2021.

Update: Despite being on the most current list of temporary telehealth codes, CMS published corrections for 鈥渢echnical errors鈥� to the calendar year (CY) 2021 Medicare Physician Fee Schedule (MPFS) in the Federal Register on March 18, including additions previously made to the Medicare telehealth services list. Four codes were 鈥渋nadvertently鈥� put on the 鈥淐ategory 3鈥� list that shouldn鈥檛 have been added, CMS says in the notice. The agency is removing the codes with the change retroactive to Jan. 1, 2021. The four CPT^庐 codes impacted include:

• 99221-99223 (New or Established Patient Initial Hospital Inpatient Care Services...)
• +96121 (Neurobehavioral status exam (clinical assessment of thinking, reasoning and judgment, [eg, acquired knowledge, attention, language, memory, planning and problem solving, and visual spatial abilities]), by physician or other qualified health care professional, both face-to-face time with the patient and time interpreting test results and preparing the report; each additional hour (List separately in addition to code for primary procedure)

Review the notice at .

Tip 2: Master Telehealth Documentation

Coding for telehealth services takes some know-how since you鈥檙e often using the same codes you might use in a face-to-face patient encounter.

Here鈥檚 how: You should document telehealth services the same way you would for any face-to-face patient encounter, but 鈥測ou should also indicate that the visit took place via telehealth and the mode of communication, along with the patient鈥檚 location, the provider鈥檚 location, the names of all persons participating in the telemedicine service, and their role in the encounter,鈥� explained Lori Langevin in a recent NGS Medicare Webinar. 鈥淔or time-based services, you can document the stop/start time or the total time,鈥� she said.

Don鈥檛 forget that 鈥測ou need to append modifier 95 (Synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system) to services performed via telehealth on or after March 1, 2020 and for the duration of the PHE,鈥� Langevin said. 鈥淢odifier 95 indicates to the payer that the service was telehealth, and your payment will not be reduced. Payers other than Medicare may not require this modifier.

Place: The place of service (POS) during the PHE is the same as what it would have been if the visit had happened face to face, such as office or hospital inpatient, according to Medicare rules.

A/V services: Don鈥檛 forget that telehealth refers to services that include audio and video components. If you鈥檙e coding for a phone-only visit, you should turn to codes such as 99441-99443 (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鈥�). 鈥淭hese are telephone E/M services,鈥� said Nathan L. Kennedy, Jr., CPC, CHC, CPPM, CPC-I, CPB, CPMA during the NGS Webinar.

Establish care: Suppose you see a new patient via telehealth, and then that person later comes to your office 鈥� is that an established patient? 鈥淐MS did indicate a few months ago that the new versus established patient guidelines are still in place,鈥� Kennedy said. 鈥淪o, if you鈥檙e providing a professional service to a patient during the PHE, they鈥檒l be an established patient when the PHE is over. CMS has said if anything changes in this regard, they鈥檒l publish additional guidance.鈥�

Keep up with resources: The Feds keep updating telehealth information, which you can access at and .

Tip 3: Look to Telehealth鈥檚 Future

With some temporary telehealth codes slated to expire with the PHE and some at the end of the PHE year, you may wonder if the Feds might make the telehealth changes permanent.

There is legislation in Congress to do so. But without a change to the law, Medicare does not have statutory authority to pay for telehealth to beneficiaries outside of rural areas or, with certain exceptions, allow beneficiaries to receive telehealth in their home, according to MLN Connects Dec 1, 2020 Special Edition.

鈥淭he PHE has allowed CMS to bypass the Social Security Act, which is federal law, to allow telehealth services to be performed outside the scope in which they鈥檙e defined in that law,鈥� Kennedy said.

However, once the PHE expires, 鈥渢elehealth services will only be allowed for patients at a distant site, they will only apply to patients who are in rural, underserved areas, and all the legislation will go back into place,鈥� Kennedy noted.

Although the official end of the current PHE extension is April 21, a Department of Health and Human Services (HHS) letter to state governors indicates that the PHE will likely extend through the end of 2021.

鈥淭o assure you of our commitment to the ongoing response, we have determined that the PHE will likely remain in place for the entirety of 2021,鈥� HHS Acting Secretary Norris Cochran said in the Jan. 22 letter. 鈥淲hen a decision is made to terminate the declaration or let it expire, HHS will provide states with 60 days鈥� notice prior to termination.鈥�

The letter specifically mentions telemedicine as a tool to increase access to healthcare during a PHE. 鈥淧redictability and stability are important given the foundation and flexibilities 鈥� that are tied to the designation of the PHE,鈥� Cochran maintains.