Telemedicine billing was challenging and confusing even before the COVID-19 pandemic thrust remote healthcare into the mainstream. Now, telemedicine is changing healthcare and evolving daily, making telemedicine billing a moving target for accounts receivable departments everywhere. Medical billing personnel must understand rules related to who's paying the bill and be aware of constantly changing regulations.
Because of telemedicine billing's complexities, healthcare providers must understand how to bill telemedicine services correctly and adopt best practices for billing.
Guidance from medical billing specialist Capture Billing advises that healthcare providers ask specific questions when structuring their telemedicine billing practices. For example, what's the telemedicine reimbursement process? Which codes should you use to bill for telemedicine services? Which restrictions should you understand when executing a telemedicine billing request?
We'll explore telemedicine billing and what healthcare professionals should know to smooth the process.
The expansion of telemedicine payers
Medicare, Medicaid and private insurance payers have boosted telehealth service access. In particular, telehealth services for Medicare and Medicaid have proliferated.
According to the Centers for Medicare & Medicaid Services (CMS), there's now vastly increased access to Medicare telehealth services, allowing beneficiaries to receive a wider range of healthcare services without traveling to a facility.
In the past, Medicare could pay for telehealth services only on a limited basis – mostly when a patient received services in a designated rural area. Now, telehealth's expansion – including 1135 waivers that remove previous service and cost requirements – allows Medicare to pay for office, hospital and other telehealth visits across the country, including in a patient's residence.
Various healthcare providers – doctors, nurse practitioners, clinical psychologists and licensed clinical social workers – include telehealth services in their offerings. Plus, the U.S. Department of Health & Human Services (HHS) provides reduced or waived cost-sharing for telehealth visits paid by federal healthcare programs.
How is telemedicine billed in Medicare?
When it comes to Medicare, telemedicine is billed by service type. According to CMS, there are three primary virtual service types for people with Medicare:
- Medicare telehealth visits
- Virtual check-ins
- E-visits
Here are some essential factors to consider when billing for telemedicine services.
- Virtual visits: Virtual visits are considered the same as in-person visits and paid at the same rate.
- Location flexibility: While patients must generally travel to or be located in certain types of originating sites, such as a physician's office, Medicare will pay for Medicare telehealth services patients receive in a healthcare facility or at home.
- Coinsurance and deductibles: The typical Medicare coinsurance fee or deductible amount would likely apply to any telehealth services received. But HHS offers some flexibility for providers to reduce or waive cost-sharing for telehealth visits covered by federal healthcare programs.
- Prior relationship with a provider: While an 1135 waiver may require an established relationship, HHS will offer leeway here during the pandemic.
Private health insurance and telemedicine
Many major commercial payers – including Blue Cross Blue Shield, Aetna, Humana and United Healthcare – cover telemedicine. According to HHS telehealth guidance, while most insurers voluntarily cover telehealth services, 42 states and Washington, D.C., legally require telemedicine reimbursement.
Because carriers will have different policies related to telehealth, healthcare providers should verify all patients' coverage scenarios before virtual appointments.
Putting telemedicine into practice
According to guidance from the American College of Obstetricians and Gynecologists (ACOG), patients are not required to have a preexisting condition for healthcare providers to conduct telehealth visits. It's also acceptable to use FaceTime, Skype and other common communication technologies to provide telehealth visits.
Billing for virtual services is the same as billing for in-office patients. From a billing perspective, both audiovisual and audio-only telehealth visits are treated as if they were in-person visits. Some payers are reimbursing for audio-only evaluations and management services using a selection of codes (see below).
Top codes for billing telemedicine services
According to ACOG, billing codes for mental health services and cardiac monitoring were added to previously approved telehealth events so providers could offer these services to Medicare beneficiaries and bill them as telehealth services.
These are the telehealth visit codes for synchronous audiovisual evaluation and management visits:
- 99201-99205: Office/outpatient E/M visit, new
- 99210-99215: Office/outpatient E/M visit, established
- G0425-G0427: Consultations, emergency department or initial inpatient (Medicare only)
- G0406-G0408: Follow-up inpatient telehealth consultations for patients in hospitals or SNFs (Medicare only)
According to ACOG, it's also important to attach Modifier 95 to these codes when billing to indicate the session was a telehealth visit. Most commercial payers require this code; for Medicare telehealth billing, you may need to use it on an interim basis.
Also, Medicare may require providers to use the Place of Service code "02" when billing for telemedicine services. However, practitioners who bill Medicare telehealth services should use the same Place of Service code they typically use when billing for in-person services during the COVID-19 public health emergency.
ACOG also states that digital evaluation and management (E/M) coding for established patients can be billed once a week; these codes can't be billed within seven days of a separate E/M service unless the patient is addressing a new problem not covered in the other E/M visit.
Capture Billing also advises following these telehealth billing practices:
- Verify insurance coverage. Confirm beforehand that the patient's insurance covers telemedicine. You should call the patient's insurance company to ensure proper billing and reimbursement for a telemedicine visit. This may be a little more work, but you'll have to do it only once per policy.
- Have insurance verification forms on hand. Ensure your staff has the proper telemedicine insurance verification forms before calling the patient's insurance provider. This helps with proper documentation and may assist in fighting denied claims.
- Know the codes. Research telemedicine billing codes for the three primary payer types – Medicare, Medicaid and private payers. When in doubt, call the payer to learn the specifics of what it needs for telemedicine billing.
Best practices for billing for telemedicine services
Technology can streamline telemedicine billing. Software-selection platform and research firm SelectHub recommends using technology that centralizes reporting and business intelligence (BI) to simplify the complex process.
SelectHub also recommends leveraging a physician dashboard and integrating the virtual billing process into larger systems, including electronic medical records (EMRs). The best EMR software can streamline a provider's workflow, from setting appointments and receiving patients to the actual provider-patient encounter – whether in person or virtual.
BI tools can help with several aspects of the telemedical billing process, offering the ability to drill down into data to visualize different datasets, including patient treatment plans, task management, and referral statistics.
Centralized physician dashboards are often customizable and help identify workload imbalances, efficiency issues, and billing issues for individual patients within the practice.