Telehealth ServicesJanuary 16th, 2021
In 2020, CMS finalized policies to cover audio-only E/M services on an interim basis. Audio-only E/M services (CPT codes 99441-43) are currently reimbursed at a rate comparable to levels 2 to 4 office/outpatient E/M visits throughout the duration of the COVID-19 public health emergency (PHE).
In its 2021 final rule, CMS stated that at the end of the PHE, there will no longer be separate payment for audio-only E/M visit codes. Instead, it is creating a new code on an interim basis. G2252 is a virtual check-in, involving 11-20 minutes of medical discussion to determine the necessity of an in-person visit, that will be available through 2021. Payment for G2252 is equivalent to payment for CPT code 99442 (wRVU of .50). CMS considers this code to be a communication technology-based service and states that it will be subject to the same billing requirements as G2012.
Additions to the Telehealth Service List
CMS added nine services to the Medicare telehealth list on a permanent basis (Category 1 basis). CMS also finalized a third temporary category for adding services to the Medicare telehealth list. This category, known as Category 3, describes services added to the list during the COVID-19 PHE that will remain on the list through the end of the calendar year in which the PHE ends.
Summary of CY 2021 Services Added to the Medicare Telehealth Services List
Type of Service
Specific Services and CPT Codes
Services finalized for permanent addition as Medicare Telehealth Services
Services finalized to remain temporarily on the Medicare telehealth list through the end of the year in which the PHE for COVID-19 ends (Category 3 services), to allow for continued development of evidence to demonstrate clinical benefit and facilitate post-PHE care transitions.
Frequency Limitations in Nursing Facility Settings
CMS finalized a policy to allow subsequent nursing visits to be furnished via Medicare telehealth once every 14 days in the nursing facility setting. CMS is not finalizing any revisions to the frequency limitations on inpatient visits or critical care consultations provided as telehealth services.
Direct Supervision by Interactive Telecommunication Technology
CMS finalized its proposal to allow direct supervision to be provided using real-time, interactive audio and video technology through the later of the end of the calendar year in which the COVID-19 PHE ends or Dec. 31, 2021.
Communication Technology-Based Services (CTBS)
CMS finalized its proposal to allow non-physician practitioners (NPPs), such as licensed clinical social workers (LCSWs), clinical psychologists, physical therapists (PTs), occupational therapists (OTs), and speech language pathologists (SLPs) to bill G2061 through G2063 (otherwise known as eVisits), consistent with the scope of these practitioners’ benefit categories.
The eVisit G codes will now be replaced with CPT codes 98970-98972. CMS also finalized its proposal to allow billing of G2250 (Remote assessment of recorded video and/or images submitted by an established patient (e.g., store and forward) and G2251 (virtual checkin) by certain NPPs, consistent with the scope of these practitioners’ benefit categories.
CMS will identically value G2250 and G2251 to G2010 and G2012, respectively. Finally, CMS finalized its proposal to designate G2250, G2251, G2061, G2062, and G2063 as “sometimes therapy” services to facilitate billing of these codes by therapists.