Betsy Nicoletti, MS


April 27, 2020

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 outlines some key guidance for using telemedicine. These rules would apply during the Centers for Medicare & Medicaid Services (CMS) emergency rule expanding the use of the technology during the coronavirus pandemic.

Selecting the Right Level of Service for Telehealth Visits

Q: I'm a family medicine physician new to telemedicine. How do I select the level of service for office visits via telehealth? Don't new patients require an in-person exam first?

A: New-patient visits may be billed via telehealth and don't require an in-person exam first. When performing a new- or established-patient visit via telemedicine, documentation guidelines require the clinician to select the level of service, based either on the key components of history, exam, and medical decision-making or on time, if counseling dominates the visit.

On March 30, 2020, however, CMS set new guidance for billing evaluation and management (E/M) services via telehealth amid the COVID-19 pandemic. The effective date for these changes is March 1, 2020, prior to the published rule.

CMS said that a practitioner could use total time or medical decision-making alone to select the level of E/M services. During the time of the public health emergency, however, history and exam are not key components in selecting the code. This mirrors the upcoming 2021 E/M changes.

If using time, CMS no longer requires that the visit be dominated by counseling. CMS said, "with time defined as all of the time associated with the E/M service on the day of the encounter." Do not include staff time.

If using medical decision-making to select the level of service, use the definition in the 1995/1997 documentation guidelines.

Any specialty physician, nurse practitioner, or physician assistant may perform telehealth services. Telehealth services may also be done by social workers and clinical psychologists, and by registered dietitians and nutrition professionals. For Medicare patients, there is a full list of services that may be performed via telehealth in this fact sheet.


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