April 6, 2020

APMA is working hard to make sure members have access to the most up-to-date information on recent changes to how and what services podiatric physicians can provide to patients via non face-to-face services. As of March 30, the biggest changes for Medicare and Medicare Advantage patient billing are the following:

• non-face-to-face services can now be provided to both new and established patients;
• providers will now be reimbursed for certain E/M-type services provided via only a telephone visit; and
• when providing telehealth, providers should now bill using 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), with modifier 95.

The March 30 rule changes are retroactively effective for any services provided on or after March 1. For providers who had a Telephone E/M service denied (CT 99441-99443) that was performed after March 1, but before March 30, APMA recommends resubmitting that claim because these changes are retroactive to March 1.

Members can review all of these changes at www.apma.org/EMremote. APMA will share a podcast in the coming days that addresses all of these updates and resources as well.

Private Payer Resource Page

As noted, the CMS-issued guidance and rules only apply to Medicare and Medicare Advantage patients during the COVID-19 crisis. To assist members with changes to coverage for non-face-to-face services under private and commercial payers, APMA has created a resource page with links to the majority of private payers’ policies at www.apma.org/COVID19telehealthprivate. 

Please note that coverage varies by individual policy. APMA also anticipates that private payers will update and change these living links, leaving possibly no reference to the previously existing policy. To protect yourself in the case of an audit or denial, APMA recommends members take the following steps:

1. Check the non-face-to-face services policy of the patient's insurance policy prior to providing non-face-to-face services for a patient
2. Print or save via PDF a time-stamped copy of that policy, and place in the patient’s record for future reference in the event of denial or an audit

APMA will add more commercial payer policies as they become available. If you know of a coverage policy for an insurer not listed on this page, please email the APMA Health Policy and Practice Department at healthpolicy.hpp@apma.org.

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