Update: CMS guidelines on telehealth and e-visits are being continuously updated as the COVID-19 pandemic progresses. For more current information on how CMS views e-visits, see our FAQ on the subject. We will continue to publish updates on the most up-to-date direction coming from CMS as this situation unfolds.
Earlier this week, the Centers for Medicare & Medicaid Services (CMS) moved to allow therapy providers to conduct a limited form of telehealth referred to as an “e-visit.” While we don’t have the full picture yet of how this will work, let’s talk about what we know so far from the guidance from CMS and the American Physical Therapy Association (APTA).
To be clear, an e-visit is not full telehealth. It is a way to check in, assess, communicate, and educate your existing Medicare patients. CMS defines an “e-visit” in the Physician Fee Schedule as “non face-to-face patient-initiated digital communications that require a clinical decision that otherwise typically would have been provided in the office.” As the COVID-19 pandemic continues, perhaps we may see additional extensions to telehealth that allow for the provision of services.
How is this going to work?
The visit must be initiated by an existing patient via a patient portal. After the provider responds, there is a seven-day window to provide “qualified nonphysician health care professional online assessment and management service.”
Who can conduct an e-visit?
Physical therapists, occupational therapists, speech-language pathologists, social workers, nurse practitioners, and more. Physical and occupational therapy assistants can not conduct an e-visit.
What services can I provide?
Using your clinical judgment, short-term assessment, management, communication, and education. This can include assigning a home exercise program to your patient over a telehealth platform.
How do I bill for this?
Clinicians billing Medicare Part B will use the CR modifier (per CMS guidance) and the three codes below, based on how long the visit lasted: 5 to 10 minutes, 11 to 20 minutes. or 21 or more minutes. Communication can be intermittent in that period, but only one code can be used for the cumulative time in the seven-day period, which begins when clinicians respond to the request.
- G2061: Qualified nonphysician health care professional online assessment and management, for an established patient, for up to seven days; cumulative time during the seven days, 5 to 10 minutes.
- G2062: Qualified nonphysician health care professional online assessment and management service, for an established patient, for up to seven days; cumulative time during the seven days, 11 to 20 minutes.
- G2063: Qualified nonphysician qualified health care professional assessment and management service, for an established patient, for up to seven days; cumulative time during the seven days, 21 or more minutes.
What do I document?
Your documentation needs to reflect that the appointment was an e-visit, was initiated by the patient, and that the patient consented to participate in an e-visit (consent can be verbal).
How can I conduct the visit?
CMS is flexible on this right now, including non-HIPAA-compliant video-conferencing tools to handle the emergency. However, CMS also expects “good faith” efforts on behalf of all providers during this period, and we should not expect lax enforcement to continue for very long.
How much will I be paid for these?
Check the physician fee schedule lookup tool.
Where can I get more information?
- MLN Matters: Medicare Fee-for-Service (FFS) Response to the Public Health Emergency on the Coronavirus (COVID-19)
- CMS: Medicare Telemedicine Health Care Provider Fact Sheet
- APTA: Furnishing and Billing E-Visits: Addressing Your Questions
Disclaimer: The information in this blog post (“Post”) is provided for general informational purposes only, and may not reflect the current law in your jurisdiction. No information contained in this Post should be construed as legal advice from MedBridge, Inc., or the individual author, nor is it intended to be a substitute for legal counsel on any subject matter.