COVID-19 Update: Podiatrists Can Provide E/M Services Remotely | News | APMA
COVID-19 Update: Podiatrists Can Provide E/M Services Remotely

April 9, 2020

Learn more about COVID-19

During the COVID-19 Public Health Emergency, there are four main non-face-to-face service types podiatrists can provide. A podiatrist’s ability to employ these services and be reimbursed for these services may differ based on the patient’s insurance and state licensure. Always check with payer and state licensure guidelines before providing any service.

For all of the services described below, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health-care providers who serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 emergency. 

The four main non-face-to-face service options include:

  1. Telehealth — Services that are normally furnished in person which are instead furnished remotely using interactive, real-time telecommunication technology
  2. Medicare Virtual Check-in
  3. Telephone E/M services
  4. Online digital E/M services

During the PHE, CMS and some other payers are allowing all four of these services to be provided for both new and established patients.

Additional Resources:

  1. Watch a video summarizing this information
  2. Listen to a podcast about this information

1. Telehealth services that are normally furnished in person which are instead furnished remotely using interactive, real-time telecommunication technology

During the PHE, CMS and some other payers are allowing certain services to be provided via telehealth  with the provider in any location and the patient in any location.

  • For Medicare beneficiaries, providers can use this option for office or other outpatient evaluation and management (E&M) services (CPT® 99202–99215) and all services listed here
  • Must use a communication tool that allows live, real-time interactive audio and video communication
  • Providers are permitted to reduce or waive cost-sharing for these services if they wish
  • Append modifier 95
  • Use the Place of Service that would have been used had the service been rendered in person (e.g., POS 11 for CPT 99213 and POS 32 for CPT 99307)
  • These services will be paid at the regular, in-person rate by CMS during the PHE.
  • This waiver is in place as long as the PHE declaration lasts
  • Postoperative global periods apply
  • Does not need to be patient initiated
  • Document a progress note as if this service was provided face-to-face. This interaction is an E&M service and E&M documentation requirements apply. The level is selected based on the 1995 or 1997 CMS guidelines for evaluation and management services, except when using CPT 99202-99215, in which case the level is selected based on Medical Decision Making alone or total time alone as illustrated by the AMA CPT Office or Other Outpatient E&M Guidelines.

2. Medicare virtual check-in

  • 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 seven 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
  • G2252 - Brief communication technology-based service, eg, 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 seven 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
  • Payable by Medicare Part B and Medicare Advantage
  • Can be any type of telecommunication tool, including telephone
  • CANNOT relate to any service in the last seven days
  • CANNOT result in patient coming in within the next 24 hours or soonest available appointment
  • Must be patient initiated
  • No modifiers needed
  • Providers are permitted to reduce or waive patient cost-sharing for these services if they wish

3. Telephone E/M services 

  • This interaction is an E/M service and documentation must support an E/M just like any other E/M type. Must have history, as much of an evaluation as possible, and some form of medical management.
  • Must be initiated by patient or the patient’s guardian
  • Payable by Medicare and some non-Medicare payers during the PHE
  • CANNOT report if call results in decision to see patient within 24 hours or next available urgent appointment
  • CANNOT report if call refers to E/M service performed by same provider within previous seven days
  • CANNOT report if call refers to a problem for which a patient is in a global period
  • CANNOT report if provider performed a telephone E/M or online digital E/M for the same patient for the same problem in the last seven days
  • CANNOT report if the call is part of Home Care Oversight Services, Care Plan Oversight Services, Home/Outpatient INR Monitoring, Complex Care Management Services, or Transitional Care Management Services
    • CPT 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 seven 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
    • CPT 99442– ; 11–20 minutes of medical discussion
    • CPT 99443– ; 21–30 minutes of medical discussion

 4. Online digital E/M services 

  • This interaction is an E/M service and documentation must support an E/M just like any other E/M type. Must have history, as much of an evaluation as possible, and some form of medical management.
  • Examples of digital platforms:
    • Electronic health record
    • Email
    • Text message
    • Other two-way digital communication
  • Must be initiated by patient via a digital platform
  • Payable by Medicare and some non-Medicare payers
  • Providers are permitted to reduce or waive patient cost-sharing for these services if they wish
  • CANNOT report if service refers to a problem for which a patient is in a global period
  • CANNOT report if service is initiated within seven days of any E/M for same problem
  • CANNOT report if performed on same day as in-person E/M service
  • CANNOT report if service is part of Home Care Oversight Services, Care Plan Oversight Services, Home/Outpatient INR Monitoring, Complex Care Management Services, or Transitional Care Management Services
  • Time spent is cumulative time over seven days starting with review of the request
  • Can only report once per seven-day period
  • Time includes:
    • Review of inquiry
    • Review of patient records
    • Interaction with other staff
    • Development of management plan
    • Rx
    • Ordering tests
    • Communication with patient
  • Add time if multiple providers in same practice perform this service for the same patient over the same seven-day period
  • If within seven days of the initiation of an online digital E/M service, a separately reported E/M visit occurs, then the provider work devoted to the online digital E/M service is incorporated into the separately reported E/M visit
  • CPT 99421: Online digital evaluation and management service, for an established patient, for up to seven days, cumulative time during the seven days; 5–10 minutes
  • CPT 99422  ; 11–20 minutes
  • CPT 99423  ; 21 or more minutes

APMA suggests obtaining informed consent for these services. APMA further suggests that members advise patients that there will be a charge for these services, that copays and deductibles may apply, and referrals may be necessary if required by the insurance plan.

5. Watch a video summarizing this information

6. Listen to a podcast about this information

We have recorded a special episode of The APMA Podcast about providing telemedicine services. Listen below.

References:

HHS Notification of Enforcement Discretion for Telehealth Remote Communications During the COVID-19 Nationwide Public Health Emergency - https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html

Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency http://hhs.com/assets/docs/covid-final-ifc.pdf

CMS Fact Sheet: https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet

Current Procedural Terminology (CPT®) is copyright 1966, 1970, 1973, 1977, 1981, 1983–2020 by the American Medical Association. All rights reserved. CPT is a registered trademark of the American Medical Association (AMA). Reference: 2020 CPT Professional

CPT codes and their descriptions do not reflect or guarantee coverage or payment. The existence of a CPT / HCPCS code does not guarantee payment for the service it describes. Coverage and payment policies of governmental and private payers vary from time to time and for different areas of the country. Questions regarding coverage and payment by a payer should be directed to that payer. APMA and its employees, consultants, and officers do not claim responsibility for any consequences or liability attributable to the use of any information, guidance, or advice contained in this communication or liability attributable to the use of any information, guidance, or advice contained in this communication.


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