CMS answers more key questions on telehealth billing during COVID-19

The Centers for Medicare & Medicaid Services (CMS) released additional frequently asked questions (FAQs) on May 27 related to Medicare billing during the COVID-19 public health emergency (PHE). The FAQs are relevant to physicians, rural health clinics, and others.

Among the new questions is one addressing Medicare annual wellness visits (AWVs) conducted via telehealth. Asked whether patient-provided vital signs can satisfy that portion of the AWV, CMS states, “If the beneficiary is at home and has access to the types of equipment they would need to self-report vital signs (e.g., weight, blood pressure), and if the visit meets all other requirements of the code, this scenario would satisfy the requirements for purposes of billing the AWV code.” This is consistent with what CMS staff said during a recent Office Hours call. CMS has not yet released guidance on how to handle a telehealth AWV when patients aren’t able to collect their own vitals.

Another new question addresses whether a visit can still be billed as Medicare telehealth if the video connection is lost during the visit due to technological issues. The answer seems to depend on how much of the visit was completed before the video cut out. CMS states, in part:

"If the service was furnished primarily through an audio-only connection, practitioners should consider whether the telephone evaluation and management or assessment and management codes best describe the service, or whether the service is best described by one of the behavioral health and education codes for which we have waived the video requirement during the PHE for the COVID-19 pandemic. If the service was furnished primarily using audio-video technology, then the practitioner should bill the appropriate code from the Medicare telehealth list that describes the service."

Other new questions and answers address the application of modifiers CS (cost sharing for COVID-19 testing and visits related to testing) and CR (catastrophe/disaster related), documentation of telehealth services in the medical record, and audio-only services lasting longer than 30 minutes. There are also a series of FAQs specifically aimed at rural health clinics and federally qualified health centers.

— Kent Moore, Senior Strategist for Physician Payment at the American Academy of Family Physicians