Telehealth Billing Basics for Virtual Patient Care
With the sudden need to respond to COVID-19, medical professionals and alternative practitioners are scrambling to provide services. Telehealth appointments for patient care are rapidly becoming the new normal.
Fortunately, many providers can offer help to their patients in this format. But there may be a steep learning curve when it comes to billing for telehealth services. This is new for many practitioners, and most have not yet needed to try this on a large scale.
Doug Fir Billing is here to help. We are learning more each day as information and updates come out, and we’re happy to share what we can.
Telehealth Billing Basics
Before you start providing remote, virtual care, check your patient’s telehealth coverage to ensure they are eligible to use this service on their plan. You need to verify that you are eligible to provide telehealth with each insurance provider. Many companies are temporarily relaxing rules due to COVID-19.
It’s essential to keep the following information in mind before you begin seeing patients or clients through virtual platforms:
To bill for telehealth appointments, you need to change the Place of Service to 2. Some exceptions noted below.
If your patient is in a different state than you are, their plan probably requires you to be licensed in the state where they are at the time of the visit.
As always, only provide services within the scope of your license. You must remain in compliance with the state laws where you and your patient are.
Emails are not considered telehealth.
If in-person services require an authorization, so do the telehealth services.
Some states have specific criteria to keep in mind. Oregon and Montana allow for video or phone visits, but Idaho and Washington only allow services through video.
HIPAA Compliance
When you are ready to start taking appointments through an online platform, you should ensure HIPAA compliance. HIPAA compliant platforms for telehealth will require you to sign a Business Associate Agreement (BAA). In this agreement, you promise that you will not violate HIPAA and will not hold the platform liable if PHI is misused.
However, the Department of Health and Human Services announced they will not be enforcing HIPAA violations during the course of the COVID-19 national emergency. The HHS recognizes that not every provider will have immediate access to compliant platforms. Their statement along with further instructions and guidelines is available here.
There are several HIPAA compliant options available for telehealth, both in the free and paid world. Double-check with the platform provider about compliance before you start seeing patients. Most platforms require an upgrade to be HIPAA compliant.
Doxy.me - has a free option
Zoom
Google Hangouts - HIPAA compliant account is $6 per month.
Gotomeeting
VSee
Modifiers
When it comes time to submit codes for online patient visits, there are some modifiers you may need to use:
GT - This is the most common modifier. Use this for interactive audio and video telecommunication.
95 - This code is very similar to GT but less common. Use it if a payer requests it instead of GT. It is for synchronous telemedicine services provided through real-time interactive audio and video telecommunication.
GQ - Most plans do not cover this rarely-used code. It would be for a situation in which a patient sends you a video, and you watch the video to provide services.
Payer-Specific Information for Telehealth Services
Optum Behavioral Health (UHC and Providence mental health)
March 27 - April 30th of 2020, Medicare, Medicaid, and commercial members are covered for appropriate behavioral health telehealth services with their providers through video or phone visits. This includes typical outpatient mental health codes such as 90837 and 90847. Details can be found here. Optum will reimburse telehealth services billed with either:
GT modifier or
Place of service 02
Please note that the only ABA Therapy codes covered are H0032, H2012, 97155, and 97156. Call the authorization department to add more hours to your authorization if medically necessary. Tell them you will be providing these codes virtually. They may need to update all current authorizations before you provide telehealth services.
Prior to COVID-19: Contracted mental health providers must sign a Telemental Health Attestation here. On the left-hand side of the page, click on the drop-down menu, “Complete Attestation Here.” Choose the form that describes you:
ABA Providers and Groups
Prescribers
Non-Prescribers
Once they confirm your validation, you can deliver Telemental Health services. Although not currently required during the pandemic, it is recommended that you get this in place.
UnitedHealthcare
Effective March 17, 2020, through April 30, 2020, all UHC patients can receive medically necessary evaluation and management services via telehealth.
There are no location requirements for commercial plans during this time. Use Place of Service 2.
GT, GQ, and 95 modifiers are ok to use.
Comercial plans should use real-time audio and video communication.
Medicare and Medicaid will reimburse phone or video visits with a caveat. Services must be for established patients who have not had related medical appointments within the past seven days.
For more details, visit the UHC telehealth page here.
Providence Health
E&M codes provided by practitioners that are contracted through ASH, such as acupuncturists, are not contracted to deliver telehealth visits at this time. ASH is currently reviewing this information with Providence and other insurance companies and will likely be updating this policy March 23rd. Check for updates by logging into your ASH account.
Providers contracted directly with Providence Health, such as MDs and NDs, are able to bill common evaluation and management codes such as 99201-99203 and 99212-99214.
99423 is temporarily allowed for both new and existing patients, despite the code descriptions.
GT modifier
Place of Service 2
Regence BCBS of Oregon
Check the member’s telehealth benefits on Availity. Do a regular Eligibility and Benefit check, then click on Benefit Booklet. Choose “Medical Benefits Booklet” and click “View/Print Booklet.”
Hit Ctrl F, then type “Telehealth” in the search box or look at the table of contents for telehealth. If your patient is at home, look at their telehealth benefits. If they are in a healthcare facility, look at their telemedicine benefits. Some plans might require you to be an MDLIVE telehealth provider or a Doctor on Demand provider.
No matter what, you need to check each patient’s member handbook to verify coverage. Many self-funded plans opt out of telehealth benefits. Patients can contact their HR department about adding this benefit.
Here are some frequently-used evaluation and management codes that Regence will cover: 99201-99203 and 99212-99214. Regence will cover these frequently-used mental health codes: 90791, 90837, 90847.
Must use GT modifier for all service
Keep Place of Service as 11 or your regular Place of Service
Unfortunately, there are no covered telehealth codes for ABA Therapy. Parents with children who require ABA Therapy should call the number on the back of their card. They will need to explain the detrimental effect this will have on their family during our current pandemic.
They also can file a complaint with the US Department of Health and Human Services Office for Civil Rights.
Access more covered codes and details about telehealth billing through Regence BCBS.
Additional information is available through their Provider Library and their Provider Contact Center. You can also call them at 1-800-253-0838.
Moda
If you have not yet registered for the Moda Benefit Tracker, you can do that here. Then log into the Moda Benefit Tracker. Before you select the member name, click “Medical Benefits to Bill.” On the top right, you will see “Member Handbook.” March 27 - April 30th, telehealth benefits are expanded.
Click on the link, and you will see a PDF file of the plan and what’s covered. Search “telehealth” or “telemedicine” to determine if the member has coverage for virtual services.
Moda reimburses most telemedicine evaluation and management services.
Moda allows for most behavioral health services to happen through telemedicine.
BCBAs are eligible to provide telemedicine. Covered codes: *Updated* March 6 - June 6, all ABA Therapy codes are covered when provided through telehealth.
Telemedicine through Moda must use real-time, interactive video. Use the GT modifier and POS 02 to indicate this technology.
For more information, look over this Moda telehealth page.
Pacific Source
When checking eligibility, look for telemedicine visits under Professional Services.
Pacific Source allows the GT modifier but does not require it.
Use Place of Service 02
Most evaluation and management services are reimbursable through telemedicine.
Pacific Source allows providers to perform most behavioral health services through telemedicine.
All ABA Therapy codes are currently covered through telemedicine.
Pacific Source offers telemedicine FAQs under the information on COVID-19 here.
Cigna
All Cigna members have automatic approval to receive mental health services such as outpatient therapy, ABA Therapy, Medication Management, and EAP services via telehealth. These services can be from an individual provider or through outpatient clinics. Currently, these are available through May 31, 2020.
Typically, Cigna only covers video services. But through May 31, 2020, Cigna is allowing phone calls for patients that don’t have access to video capabilities.
Cigna is currently lifting the requirement that you sign the attestation before providing telehealth services.
Cigna is lifting location restrictions temporarily.
Use Modifier 95 and POS 02 to specify telehealth.
Updates are pending for coverage of medical evaluation and management services through telehealth platforms. This is likely to continue to evolve, so keep checking with Cigna for up-to-date information.
Care Oregon
Care Oregon is covering telemedicine services for all patients, when medically necessary. No modifier required, GT accepted.
Most evaluation and management services are reimbursable through telemedicine.
Most behavioral health services can be performed through telemedicine.
Telephone services are reimbursable, but use POS 11 or your regular place of service code. Video service require POS 02.
Care Oregon will continue to follow OHA guidelines and post updates on their site.
Doug Fir Billing Is Here for You
Here in the Pacific Northwest, Doug Fir Billing is working to help providers whenever we can. However, things are changing by the hour as new information becomes available. Continue to check with payers regarding changes and updates.
This is a trying and overwhelming time for everyone, especially those in the medical field. We wish you continued health, peace, and wellness as we all work together in the coming days, weeks, and months.