Reimbursement for providing telemedicine services
By C. Matthew Hawkins, MD Summer 2017
Q: My hospital continues to invest in contemporary technology that allows for remote patient visits via telemedicine/telehealth services. They continue to encourage physicians to use these tools to decrease the travel burden on our patients. Can we get paid for providing telemedicine services?
A: Yes! In fact, these new reportable evaluation and management (E&M) encounters offer some exciting potential for interventional radiologists, as many/most of our practices are centered in urban areas that can be hard for some of our patients to reach. Additionally, since there are relatively few interventional radiologists across the country, telemedicine potentially expands the reach and capacity of our specialty. Through telemedicine, IRs can report E&M services for both outpatients and inpatients. There are some caveats, of course, though.
First, the service must be a synchronous audio and video encounter, which is defined as “a real-time interaction between a physician or other qualified health care professional and a patient who is located at a distant site from the physician or qualified health care provider.”
Second, the AMA CPT 2017 Professional Coding Manual states that “the totality of the communication and information exchanged between the physician … and the patient during the … service must be an amount and nature that would be sufficient to meet the key components and/or requirements of the same service when rendered via a face-to-face interaction.”
When evaluation and management services are provided via a synchronous telemedicine encounter, modifier 95 should be appended to the E&M service performed. For IRs, the most common E&M codes that can be reported via telemedicine services include outpatient E&M services (99201–99205, 99212–99215, 99241–99245), subsequent hospital services (99231–99233) and inpatient consultations (99251–99255). Appendix P in the CPT Manual lists all the codes that can reported via telemedicine.
Many states have additional regulations that may need to be met to appropriately report these codes, so working closely with your hospital compliance and coding teams will be useful if your group chooses to offer these services.
Q: What if I spend time talking to a patient on the phone? Is there a CPT code that can reported for that service?
A: Yes, but these services are not considered telehealth services, as there is not a synchronous audio and video encounter when speaking via the telephone. Pages 39–41 of the 2017 CPT Professional Coding Manual delineate the non-face-to-face E&M services that can be reported: 99441–99443 can be reported for phone conversations initiated by patients that do not involve a recent E&M encounter within the prior 7 days and are not in the postoperative period. If, on the basis of the telephone call, a decision is made to see the patient within the next 24 hours, then 99441–99443 should not be reported. Rather, the encounter is considered part of the preservice work of the subsequent E&M encounter.
Furthermore, communication with patients via online EMR tools not originating from an E&M encounter in the prior 7 days can be reported with code 99444.
Lastly, IRs often spend time consulting with other health care professionals via the telephone/internet. These services, in the appropriate settings, can be reported via codes 99446–99448. These codes should not be reported by a physician who has agreed to accept transfer of care or when the telephone consultation leads to a face-to-face encounter (such as a procedure) within the next 14 days.
Because a number of additional caveats pertain to appropriate reporting of the non-face-to-face patient encounter codes, it is important for IRs to work with their coding and compliance teams to properly report these services.