COVID Coding Conundrums
CODING
Kathy Mills Chang
MCS-P, CCPC, CCCA
Indeed, we’re always hoping to learn new things but WOW, we didn’t expect to be immersed in so many new things at once. In the world of Healthcare, depending on your specialty, you may be experiencing a world of new considerations that you didn’t know you needed. A few of the new things that you need to know include coding for evaluation and management rendered through telemedicine or treatment at a patient’s home. Some practices may also need to know diagnosis codes for the disease itself and for testing and treatment. This brief overview brings these issues into focus and provides some immediate, useful information.
Telemedicine Considerations
When adding telemedicine to your practice in response to Covid-19, be aware of the many considerations necessary. Billing Medicare for these services ordered or delivered by a chiropractor would be excluded from coverage as Medicare only covers spinal CMT services. Telemedicine services for Medicare patients would be submitted to Medicare as a statutorily excluded service utilizing the GY modifier.
Steps to consider:
1.Contact your Malpractice carrier to ensure you have telemedicine coverage.
2. Contact your state board to determine if you can perform telehealth as part of your licensure (changing frequently).
3. Contact the payers you plan to bill regarding coverage of telemedicine services (most are allowing) and ask if they require 02 as the place of service and the 95 modifier. On their websites, search for a medical review policy that outlines the rules for billing telemedicine.
4. Find a video format that works with your office to determine a way to record these services.
5. Inquire whether your state requires a specific Informed Consent for Telehealth services.
Documentation standards still exist, and care must be medically necessary. Make sure to include in your documentation something like “services provided via telehealth.”
• Effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency.
The HHS Office for Civil Rights (OCR) announced on March 17, 2020, that it will waive potential HIPAA penalties for good faith use of telehealth during the nationwide public health emergency. Normally, Providers would have to use a secure means of communication. However, with this announcement, non-HIPAA approved technologies like Skype and FaceTime can be used. (Facebook Live, TikTok, and similar video communication applications are public facing and should not be used in the provision of telehealth by covered health care providers.) See the HHS Notice for HIPAA for more details at https://www.hhs.gov/hipaa/for-professionals/ special-topics/emergency-preparedness/index.html.
Coding Telemedicine Correctly
When performed by a physician, CPT codes 9942199423 are used. These are only used for established patients who have not had an in-office E/M service billed by the same provider within the same 7-day period. However, in light of the ongoing crisis, CMS has broadened the definitions to include New Patients as well. Ensure that third-party payers who may be billed allow the same. Telemedicine codes are time-based and reflect the cumulative time spent in a telemedicine service over a 7-day period. These codes should be billed as follows:
• 99421: Online digital evaluation and management service for an established patient for up to 7 days. Cumulative time: 5-10 minutes.
• 99422: Online digital evaluation and management service for an established patient for up to 7 days. Cumulative time: 11-20 minutes.
• 99423: Online digital evaluation and management service for an established patient for up to 7 days. Cumulative time: 21 or more minutes.
Since the service is being performed electronically versus a traditional office visit, a different place of service (POS) code must be reported in Box 24b on the 1500 claim form. Code “02” indicates that the E/M service was performed via telehealth. Additionally, if the telemedicine visit is synchronous - meaning that the interaction is a live 2-way audiovisual communication -the -95 modifier should be attached to the telemedicine E/M service code being billed.
Coverage Considerations
When it comes to billing third-party payers for this service, we apply the Golden Rule: He who has the gold makes the rules. That means that the payer will decide the following:
1. Is telemedicine a covered service?
2. If it is a covered service, which provider types are eligible for reimbursements?
3. Is there a limitation as to how many telemedicine visits are approved?
4. What are the medical necessity elements necessary for reimbursement?
Check with each payer’s medical review policy to determine whether policy exists regarding these components.
What About Home Visits?
You may elect to see patients in their homes during this difficult time. Of course, practice all social distancing requirements to the best of your ability, limiting the number of persons in the home while you are there treating.
Chiropractic treatment rendered in the patient’s home is no different than care rendered in the office from a billing perspective, other than using the place of service code 12 in Box 24b of the 1500 claim form, vs. code 11 for office.
COVID-19 and the subsequent “shelter in place” and “stay at home” orders are changing rapidly. Stay tuned to communications from your state board of examiners and other regulatory agencies regarding the fluidity of changes in this arena. There are also 100 opinions from 100 people on whether Chiropractic is deemed essential. Your board and those rules will take precedent.
We’ll get through this, together. This is just one more thing to learn and add to our arsenal of education around healthcare reimbursement and compliance. We’ll see you on the other side of this!
For a full list of the updated rules regarding telemedicine indicated the change in requirements go to the following link: https ://www. cms.gov/newsroom/factsheets/medicare-telemedicine-health-care-providerfact-sheet
It’s important to know the interpretation as viewed by CMS, because although they do not cover chiropractic care in this sense, other third-party payers use the CMS interpretations as guidelines in justifying care.
Kathy Mills Chang is a Certified Medical Compliance Specialist (MCS-P), Certified Chiropractic Professional Coder (CCPC), and Certified Clinical Chiropractic Assistant (CCCA). Since 1983, she has been providing chiropractors with reimbursement and compliance training, advice, and tools to improve the financial performance of their practices. Kathy leads the team of KMC University specialists and is known as one of our professions foremost experts on Medicare, documentation and CA development. Kathy or any of her team members can be reached at (855) 832-6562 or [email protected]
