In response to the public health emergency (PHE) for the COVID-19 pandemic, CMS undertook emergency rulemaking to add a number of services to the Medicare telehealth services list on an interim final basis, including communication technology-based services (CTBS).

CMS is now considering which of those services should remain on the Medicare telehealth services list permanently after the end of the PHE.

The good news is: CMS is proposing to add the services in Table 8 on page 82 of the proposed rule (https://www.cms.gov/files/document/cms-1734-p-pdf.pdf) to the Medicare telehealth services list on a Category 1 basis (services that are similar to professional consultations, office visits, and office psychiatry services that are currently on the Medicare telehealth services list) for CY 2021. See page 94 for the proposed list for temporary additions to the list.

Type of Service – Specific Services and CPT® Codes

Services CMS is proposing a permanent addition to the Medicare telehealth services list.
-Group Psychotherapy (CPT® code 90853).
-Domiciliary, Rest Home, or Custodial Care services, Established patients (CPT® codes 99334-99335).
-Home Visits, Established Patient (CPT® codes 99347- 99348).
-Cognitive Assessment and Care Planning Services (CPT® code 99483).
-Visit Complexity Inherent to Certain Office/Outpatient E/Ms (HCPCS Level II code GPC1X).
-Prolonged Services (CPT® code 99XXX).
-Psychological and Neuropsychological Testing (CPT® code 96121).

Services CMS is proposing as temporary additions to the Medicare telehealth services list.
-Domiciliary, Rest Home, or Custodial Care services, Established patients (CPT® codes 99336-99337).
-Home Visits, Established Patient (CPT® codes 99349-99350).
-Emergency Department Visits, Levels 1-3 (CPT® codes 99281-99283).
-Nursing facilities discharge day management (CPT® codes 99315-99316).
-Psychological and Neuropsychological Testing (CPT® codes 96130- 96133).

CMS is also proposing to allow billing of other CTBS by certain nonphysician practitioners (NPPs), consistent with the scope of the practitioners’ benefit categories through the creation of two additional HCPCS Level II G codes that can be billed by practitioners who cannot independently bill for E/M services:

HCPCS Level II Code – Descriptor

G20X0 – Remote assessment of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment.

G20X2 – Brief communication technology-based service, e.g. virtual check-in, by a qualified health care professional who cannot report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.

CMS is proposing to value these services identically to HCPCS Level II codes G2010 and G2012, respectively.

To facilitate billing of the CTBS by therapists, CMS proposes to designate HCPCS Level II codes G20X0, G20X2, G2061, G2062, and G2063 as “sometimes therapy” services. When billed by a private practice physical therapist (PT), occupational therapist (OT), or speech-language pathologist (SLP), the codes would need to include the corresponding GO, GP, or GN therapy modifier to signify that the CTBS are furnished as therapy services furnished under an OT, PT, or SLP plan of care. In section II.K. of this proposed rule CMS is proposing for CY 2021 to replace the eVisit G codes with corresponding CPT® codes, and this policy would also apply to those codes.

(Note from your Revenue Cycle Management partner at ebix, Inc. – We are always at the forefront of industry insights and believe this announcement Renee Dustman – Executive Editor at AAPC (American Academy of Professional Coders )will be of interest to you.)