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

March 25, 2020

Learn more about COVID-19

During the COVID-19 Public Health Emergency, there are four non-face-to-face service types podiatrists can provide to most patients. A provider’s ability to employ these services may differ based on the patient’s insurance and state licensure. Some private insurers have issued guidelines that vary from what is listed below. 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 that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 emergency.  

The four service options include:

  1. Use CPT 99202-99215 for Medicare Part B and Medicare Advantage patients when these services are provided remotely as long as the Public Health Emergency lasts. Some private payers have made the same allowance. Check private payer policies for details.
  2. Use G2012 when a virtual check-in is provided to a Medicare Part B or Medicare Advantage patient
  3. Telephone E/M services for patients with any insurance
  4. Online digital E/M services for patients with any insurance
  5. Watch a video summary of this information

1. Use CPT 99202-99215 for Medicare Part B and Medicare Advantage patients when these services are provided remotely as long as the Public Health Emergency lasts. Some private payers have made the same allowance. Check private payer policies for details.

On March 17, CMS announced that providers can submit CPT 99201–99215 when providing these services remotely. The provider can be in any location and the patient can be in any location. Since that announcement, some private payers have followed suit. 

  • Must use a communication tool that has interactive audio and video
  • Communication tool must allow real time communication
  • Providers are permitted to reduce or waive cost-sharing for these services if they wish
  • Typical HIPAA guidance does not apply to these services as long as providers are providing these services in good faith
  • No modifiers needed
  • Use Place of Service “02”
  • These will be paid at facility rate
  • This waiver is in place as long as the Public Health Emergency lasts
  • Postoperative global periods apply
  • Document a progress note just like one would do when this service is provided face-to-face. This interaction is an E/M service and the same documentation requirements apply. The level is selected based on the 1995 or 1997 CMS guidelines for Evaluation and Management services.

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

2. Use G2012 when a virtual check-in is provided to a Medicare Part B or Medicare Advantage patient using telephone interactions in addition to synchronous, two-way audio interactions that are enhanced with video or other kinds of data transmission.

  • 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
  • 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
  • Can only be used for established patients.
  • No modifiers needed

3. Telephone E/M

  • 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
  • Explained in the first half of this webinar
  • Must be an established patient
  • Must be initiated by established patient or the patient’s guardian
  • Provider may educate patients about this option
  • Not reimbursed by Medicare and some other payers
  • 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 same patient for 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
  • Explained in the second half of this webinar (starting at 9:50)
  • Examples of “Digital” platforms:
    • HIPAA-compliant EHR
    • HIPAA-compliant email
    • HIPAA-compliant text
    • Other HIPAA-compliant two-way digital communication
  • Must be an established patient
  • Must be initiated by established patient via a digital platform
  • Provider may educate patients about this option
  • Not reimbursed by Medicare and some other payers
  • 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 same patient over same seven day period
  • If within sevendays 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

5. Watch a video summary of this information

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.

Current Procedural Terminology (CPT®) is copyright 1966, 1970, 1973, 1977, 1981, 1983-2019 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. Just because a CPT code exists, payment for the service it describes is not guaranteed. 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.


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