The Critical Element in Billing Medicare for Telemedicine

Betsy Nicoletti, MS


May 28, 2019

In This Article

The Coding Expert Answers Your Questions

Editor's Note: Betsy Nicoletti, MS, a nationally recognized coding expert, will take your coding questions via email and provide guidance on how to code properly to maximize reimbursement. Have a question about coding? Send it here.

In this column, Nicoletti answers some questions received in the past few months on a variety of topics of interest to physicians.

Telemedicine Coding for Medicare Patients

Question: Our office is interested in telemedicine. What are the rules and Medicare reimbursement for coding both a telemedicine visit and a medication management telemedicine visit?

Answer: Medicare only pays for telemedicine services if the patient is in a "medically underserved area" (MUA). These are defined as areas or populations designated by the US Health Resources & Services Administration as having too few primary care providers, high infant mortality, high poverty, or a high elderly population.[1] If you think your practice area might fall under that definition, you can check it online here.

The patient's facility bills and is paid a small fee as the "originating site," and the distant physician/nurse practitioner or physician assistant bills for the service provided. You can read the transmittal here and use this tool to see if your patients are in an MUA.

Billing for Pharmacist Services

Question: I am a pharmacist practicing in an academic teaching hospital. Can you explain how internal medicine pharmacists in the acute care setting bill for services?

Question: If a physician has a collaborative agreement in place with a pharmacist, can a pharmacist perform parts of the Annual Wellness Visit, the physician complete the rest of it, and the physician then bills for it?

Answers: Although they provide valuable services to the care team, pharmacists currently are not a recognized specialty and may not enroll with Medicare to perform and bill for services. The scope of practice of pharmacists does not include providing evaluation and management (E/M) services, such as office visits or hospital visits.

The answer to the first question is that a pharmacist could not perform a service and bill Medicare Part B for consultative care in an inpatient stay. The hospital that employs the pharmacist includes that cost on its Medicare cost report.

Regarding the second question, any employed staff member in a physician practice could perform the health risk assessment and screenings required for a Medicare wellness visit or Annual Wellness Visit. This service is usually performed by a medical assistant or other clinical nursing staff. A pharmacist could not independently perform the wellness visit, as this is out of their scope of practice.


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