E-Visits and Billing Medicare: UPDATE

April 14, 2020
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Rick Gawenda
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During a Centers for Medicare and Medicaid Services (CMS) “Office Hours” call on April 14, 2020, a participant asked if E-Visits (G2061, G2062 and G2063) and Virtual Check-Ins (G2010 and G2012) could be billed on a UB-04 claim form? In addition, a question was asked if you can bill HCPCS Level II codes for more than 1 7-day period? In this article, I will answer both questions.

The answer from the CMS representative was

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  1. In an email blast from you it was mentioned can assistants perform E-visits and telephone services. You stated that it was answered on April 9th but I couldn’t find anything on your website to see if they could or not.

    please clarify for me

    Thanks Peg

  2. Can each discipline (PT, OT, and SLP) bill this code, G2063 as an example during a 7-day period if each discipline provides an e-visit during this period? Each provider completed >21 minutes of care during a 7-day period.
    So our claim would be submitted with 1 of each G2063GN, G2063GO, G2063GP.

    Thank you and your site has been such a great resource during this uncertain time.

  3. Hello Rick. When I chatted with my local MAC today (4/20/2020) they said that modifiers do not apply for telephone services since we are not providing therapy services. 2 weeks ago I was told that you’d have to use the CR & GP modifiers must be used. Today they are telling me that the system has been updated on 4/7/2020 and no modifiers are to be used for telephone service codes. I did not ask about E-visits as my clinic can’t no provide that service right now.

    1. I can tell you that in the interim final rule CMS released on March 30th, CMS stated GP, GO and GN would be required if this service was provided by a PT, OT or SLP.

  4. Rick, Thank you for helping us navigate through telehealth, evisits, etc. It seems that those of us who bill outpatient therapy services on a UB-04 are not able to provide services to our Medicare patients other than face to face therapy in the home or in the clinic? The evisit codes and the telephone codes all seem to only be billable via a 1500 form. Am I missing something?

    1. Per a CMS phone call, CMS is aware of the issue of billing E-Visits and Telephone Services on a Ub-04 claims and they are looking into it.

  5. Rick,
    Has CMS ever clarified if a telephone would be an acceptable form of communication when completing an e-visit? We have several patients where their phone is their only means of communication and these patients are not candidates for any type of in-person visit due to health concerns.
    Thank you for your help with all of our questions.

    1. Why not conduct a telephone service since that is payable by the Medicare program? In addition, CMS has not stated either way if a telephone can be used for an E-Visit. Right now, to be safe, I would say no unless CMS states otherwise in the future.

  6. I just got my first e-visit rejected when billing G2063 with GP,CR modifiers. I am talking to my MAC and being told I am supposed to use the 95 modifier instead of the CR modifier. They sent me this link to substantiate their stand:

    https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-04-03-mlnc-se

    and highlighted this part:

    “As a reminder, CMS is not requiring the CR modifier on telehealth services.”

    I will resubmit with the changes they gave me.

    1. An E-Visit is not a telehealth service. E-Visits and Telehealth Visits are not the same. CMS is aware of the issues and have said they will be issuing guidance to the Medicare Administrative Contractors in the near future.

      1. I realize there is a distinction between “telehealth” and “e-visit” and also pointed this out to the rep. We spent probably 1/2 an hour on the call while she kept checking but this is where she ended up. I asked her to back it up with documentation and this was the link she gave me. I have resubmitted the claim based on her recommendations. We will see what happens.

        1. Let me guess; your MAC is Noridian? Most MACs have interpreted that document incorrectly and CMS is aware of the mistakes that MACs are making. My opinion is you will get paid because the MAC is screwed up.

  7. This situation is pretty silly for PT/OT/SLP & Telehealth with Medicare. When Medicare added in the therapy codes it seemed to me Medicare clearly intended to include therapists in Telehealth. I figured it was just an oversight and a fix would come out quickly. It is disappointing not to see any changes after several weeks. I have written my representative and both our senators asking for help with this. Sadly, no responses. I saw the APTA acted quickly on this but as far as I can tell that action hasn’t made a difference either. Unfortunately, many other payers are also not covering therapy services using telehealth. I’m sure no small part of this is waiting to see what Medicare decides.

    1. What you may not know is that when the rule was first written, President Trump had not yet signed the CARES Act into law so CMS did not have the authority to add PTs, OTs and SLPs as telehealth providers. CMS needed to add the CPT codes commonly used and billed by PTs, OTs and SLPs as covered telehealth services and that is what they did in the rule that was published on March 30th. We are now waiting for the next rule to be released that we believe will add PTs, OTs and SLPs as temporary telehealth providers under the Medicare program.

  8. Just FYI – we spoke w/ CMS today about an e-visit claim that previously showed “payment denied when performed/billed by this type provider”. We were told that this was prior to CMS updating their system to show that the e-visit codes could now be billed by physical therapists. They stated that they have now updated their system and that we just need to refile the claim, which was for G2063 and they said to add our usual GP modifier. However, when we asked them about adding the CR, they said they could not find anything advising that we add the CR modifier and they said to refile without adding it. Just thought I would share this information. Thanks for all the updates you provide!

  9. Just to update you on my last message. We did receive back a denial today on the e-visit we billed on 4/24/20 with only the GP modifier, as CMS had advised us to do. However, we received payment today on some e-visits billed to Medicare previously WITHOUT the GP modifier, that included only the CR modifier.

  10. We just received our first denial on our E-visits from prior. The denial code was C016 – lacking information. When we called to question we were informed our modifiers were incorrect. We applied the GP and CR with place of service still being 11. Our MAC is First Coast (Florida). Should we re-bill with the same modifiers, assuming they have updated their system or should we change it to a 95? Please advise.

    1. CMS is aware of MACs having issues with E-Visits and not following the instructions correctly. You would need to contact First Coast.

  11. Can visits prior to May 1st be billed as Telehealth with Medicare or do we need to keep them as Evisits.

    1. Please read my latest article regarding retroactive date for telehealth visits. Also, an E-Visit is not the same as a Telehealth visit and can’t be billed as a Telehealth visit.