Medicare, Telehealth and the COVID-19 Public Health Emergency

Medicare has made additional changes regarding how to report and bill care provided via telehealth during the COVID-19 public health emergency.

Included below is additional information that doctors of optometry should know about new options for telehealth and appropriate coding of telehealth services.

  • Providing care to new patients via telehealth: Medicare will now allow all telehealth services to be provided to both new and established patients. This change was authorized by the CARES Act passed by Congress and signed into law on March 27.

  • Telephone based services can be reported. The CMS will now allow the use of CPT codes 99441-99443.

  • Medicare Administrative Contractors (MACs) are working to keep up with fast-moving changes. You may experience initial denials or your MAC may require certain modifiers for reporting these services. Make sure you review any MAC-specific information on billing telehealth services. An initial denial or initial coverage of a service billed may not accurately reflect a payer's policy. Report denials using the  ask the coding experts form.

  • Private insurers policies vary. Private insurers are reacting to the COVID-19 public health emergency and changing coverage policies. Please remember: even if one insurance company or one plan seems to be paying for a service provided via telehealth, not all other insurers or plans under the same insurer will have the same policies.

  • Implement appropriate billing practices. While certain previous telehealth restrictions have been waived during the ongoing public health emergency, it is important to ensure you are reporting codes approved for use via telehealth, that you are meeting the requirements of any code billed and that you document appropriately .

  • Modifier use. The CMS has clarified in rulemaking that modifier 95 should be applied to codes that are reported for telehealth services .

  • Place of service code. The CMS has clarified in rulemaking that physicians billing telehealth should report the Place of Service (POS) code that would have been reported had the service been furnished in person. The in-office place of service is 11.

  • View AOA's webinars on telehealth. AOA COVID-19 webinar series on demand

Questions? Contact  AOA's coding experts.

Information on external sites you may find helpful:

Ask the coding experts

If you have any questions regarding Medical Records and Coding, please submit them to Coding Experts Submission Form and one of our coding experts will be in contact with you.
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