E-Visits for Therapy Services
Due to the coronavirus (COVID-19) pandemic, many private practices and organizations are asking about their ability to provide therapy services to their patients via telehealth or some other type of virtual service. To read my article on telehealth services provided by physical therapists (PTs), occupational therapists (OTs) and speech-language pathologists (SLPs), click HERE.
Due to the 1135 waiver authority and Coronavirus Preparedness and Response Supplemental Appropriations Act, the Centers for Medicare and Medicaid Services (CMS) is expanding access to Medicare telehealth services so that beneficiaries can receive a wider range of services from their providers without having to travel to a healthcare facility. In this article, I will discuss E-Visits and the ability of PTs, OTs and SLPs to provide an E-Visit and the codes available to bill to the Medicare program and possibly non-Medicare insurance carriers.
An E-Visit allows an established Medicare beneficiary to have a patient-initiated non-face-to-face communication with their health care provider without physically going to the provider’s office. CMS states the E-Visit(s) must be initiated by the patient; however, the provider can educate the Medicare beneficiaries on the availability of the services prior to the patient initiation.
Question
How can a Medicare beneficiary initiate an E-Visit?
Answer
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Question
What codes can the PTs, OTs and SLPs bill for the E-Visit(s) to the Medicare program?
Answer
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Question – Updated March 31, 2020
Is there a modifier or modifiers that are required to be appended to the Level II HCPCS codes for an E-Visit?
Answer
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Question
Who is considered a qualified non-physician healthcare professional?
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Question – Updated March 31, 2020
Are physical therapist assistants (PTAs) and occupational therapy assistants (OTAs) considered a qualified non-physician healthcare professional?
Answer
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Question
Can a physical therapist assistant (PTA) or occupational therapy assistant (OTA) provide an E-Visit?
Answer (Updated April 11, 2020)
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Question
What is the payment amount for each of the above codes for Medicare beneficiaries?
Answer
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Question
What must be documented in the medical record to support the billing of an E-Visit?
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Question
What day would I bill the applicable code for the E-Visit(s) done during the 7-day period?
Answer
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Question
Can physical therapists, occupational therapists and speech-language pathologists bill and be paid for CPT codes 99421, 99422 and 99423?
Answer
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Question
On the 1500-claim form, what place of service code do we use for an E-Visit?
Answer
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Question
On the UB-04 claim form, what place of service code do we use for an E-Visit?
Answer
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Question
On the UB-04 claim form, what revenue code do I use when billing the HCPCS Level II codes for an E-Visit?
Answer Updated on March 23, 2020
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Question – Added April 9, 2020
Can institutional settings (i.e. rehab agencies, home health agencies, and hospitals) bill and be paid for the HCPCS Level II codes G2061, G2062, and G2063?
Answer
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Question
Will Medicare coinsurance and annual Part B deductible apply to these codes?
Answer
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Question
Will the amount the Medicare program pays for an E-Visit count towards the annual therapy threshold dollar amount?
Answer Updated Answer March 23, 2020
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Question
Will the therapy specific modifiers (GN, GO, GP) be required to appended to the E-Visit HCPCS Level II codes?
Answer as of March 23, 2020
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Question
What are some things to keep in mind when reporting an E-Visit(s)?
Answer
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Question
Can I bill for an E-Visit(s) for the cumulative time I’m speaking with a Medicare beneficiary on the telephone?
Answer Updated March 24, 2020
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Question
Would FaceTime and Skype constitute an online patient portal and allow me to bill for an E-Visit?
Answer
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Question
Is an E-Visit the same as telehealth?
Answer
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Question
Can I bill CPT codes 99421, 99422 and 99423 for an E-Visit(s)?
Answer
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Question
Can physical therapists, occupational therapists and speech-language pathologists bill and be paid for CPT codes 99441, 99442 and 99443?
Answer
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Question
Will non-Medicare insurance carriers pay for an E-Visit(s)
Answer
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Question
How does HIPAA factor into an E-Visit?
Answer
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For the terminology “for up to seven days, cumulative time during the 7 days”. Does this mean you can have as many e-visits during a 7 day period with that patient and the cumulative time you spent you’ll bill that specific code. So we’re only billing one code per 7 days. Do they then have to be seen in person or can the next 7 days accrue time to then bill one code?
The cumulative time is for a 7-day period and then you determine which code to bill.
So, we can’t do face time or skype with the patient to see that they are doing the exercises correctly and, we can’t bill for each interaction with the patient? The billing is for the total time spent over 7 days with the patient?
FaceTime and Skype would not be considered an online patient portal.
What about the statement from HHS OCR stating they will “exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communication technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency”??
and you are asking this question from what perspective?
FaceTime and Skype are not considered online patient portal, but would I be correct in understanding that those are appropriate to use right now ONLY during the COVID-19 nationwide health emergency (per the notice of exercise of discretion to not impose penalties for noncompliance with using non-public facing audio/visual communication) to complete E-visits?
That is what we are trying to seek clarification from CMS on. They only really discussed FaceTime and Skype as it pertained to HIPAA and not as they pertain to the 3 codes for an E-Visit. I will continue to update this article as the news and answers change.
Oh I see, thank you!
Just to verify, after the first 7 day period is finalized, the patient can be seen again via a telehealth visit (if this is determined needed) and the 7 day period would start over? There is not a limited # of telehealth visits for a patient, just the 7 day period per visit?
This is not telehealth. It’s considered an E-Visit. Billing is based on the cumulative time for a 7-day period.
So if we are billing as an E-Visit, the time billed is cumulative over a 7 day period? And then, after the initial 7 day period is over, we can initiate another cumulative billing for E-Visits over the next 7 day period?
Correct!
Thank you so much for all of your help.
You are welcome!
What would be the place of service? 02?
Thanks!
KJ
I just added an additional question answering the place of service code for an E-Visit.
If a patient request to be seen via E-visits once a week can we bill for consecutive weekly visits for an established patient?
We believe so.
Thank you very much for this prompt article!
I understand that communication has to take place via an Online Portal, though what is the method of communication? (Written, Verbal, Video, etc…)
Thank you!
It would depend on the online patient portal you are using. Most use email communication.
Also, we bill as a part A but we are paid out of part B can we still use this?
Part B benefits pays for outpatient therapy services.
Rick-
Thanks for the information and explanations. I love that you are so on top of things and can push information out in a day.
Have a great day!
Amanda Somers
Thank you for the kind words. Stressful times for many!
Does the 02 place of service code apply to the E-visits, or no because it is not telehealth and the codes themselves are enough to determine the type of visit it is?
Place of service code 02 would not be appropriate for E-Visits. I added an additional question regarding place of service code for E-Visits to this article.
Would this E-Visit capability also apply for PTAs and COTAs?
Great question! No, since PTA and OTAs are not considered qualified non-physician healthcare professionals. I will add this question to the article.
Thanks so much!
Can you bill the e-visit GCode in combination with say appropriate CPT Codes, Self-Care (97535) or Ther-Ex (97110) for example?
No. You can’t bill the usual CPT codes for an E-Visit.
How and where do we document these visits. Example, we use WebPT as our EMR. Do you still document in the EMR for each time you E-Visit or only after the end of 7 days.
Additionally, is a platform like Physitrack considered an approved platform for the video components?
If you have questions regarding how to document the E-Visits in your EMR system, that is a question to ask your EMR company. I do not recommend platforms.
Sorry Rick I know you have addressed this several times but I want to make sure I get this right…
So I have a therapist that had a E Visit today that lasted 22 mins do I bill the G2063 today for that one unit or do I wait until the 7 day period has passed and say they had several more visits, do we bill more units of that code based on the total time during those 7 days??
Sorry I have been reading so many things I just want to make sure I have a clear understanding…
Thank you for being such a GREAT resource!!!
You wait until the end of the 7-day period and can only bill 1 unit of the applicable code. The codes are not time-based.
Got cha!! Thank you so much!!
Sorry, another one. Do you have any idea if it is an option to perform an initial evaluation in person (after the patient is screened per CDC guidelines) for post-op patients to help them become established patients, and then transition to E-visits until we are no longer in a state of emergency?
I have not seen this addressed anywhere and was not sure if billing for an evaluation, then changing to Evisit billing would throw up a red flag…we are trying not to suspend evaluations of patients that we feel are time sensitive to start therapy but are not ready to fully open our clinic up yet.
That would be allowed.
This question is regarding telehealth and not evisit.
Will Medicare cover for 99441,99442 codes for telehealth .
Can you please cover on that topic too. Since patient numbers are so low my outpatient office wants us to do telehealth in NY . I am not sure how Medicare would see that . Also does it have to be initiated by a patient ?
I really appreciate your response in this
I wrote an article on telehealth and therapy. You can read it at https://gawendaseminars.com/covid-19-and-telehealth-services/
Thank you. Your response are very helpful . One more question- can the PT initiate the E visit by making a phone call instead of the emr portal ? I read in the article that it has to be emr based and initiated by patient. What if the patient is Not initiating and the therapist are calling and checking on patients – “ how are you ? How’s your pain ?” Can they bill the G2061?
Our clinic owner is saying the above scenario is acceptable to bill . This is new and I want to make sure I know right thing and not do anything just because he says it’s acceptable. Thank you again for the guidance.
CMS states the provider can educate the Medicare beneficiaries on the availability of the services prior to the patient initiation.
Thank you for the guidance.
An Evisit means non video, only Audio? So platforms like ZOOM cannot be used? I read Medicare guidelines and it is confusing.
We hope to have clarification from CMS shortly.
Were you able to get clarification on this question?
No updates from CMS at this moment.
This is very helpful. What exactly are we all planning on doing during a E-visit?
Our company bills claims with our group NPI, is that still allowed for e-visits or does billing need to be sent under the individual therapists NPI?
What NPI number is in Box 24J of the 1500-claim form?
Rick, if you are seeking clarification from CMS regarding FaceTime and Skype as it pertains to HIPAA and these 3 codes it may also be helpful to include email in that discussion. Email is a similar communication mechanism as an online patient portal, it just isn’t technically considered a HIPAA secure “online patient portal” platform. With CMS lightening the HIPAA related restrictions during this COVID situation email might be another consideration.
Thank you for all of your help and guidance!
Please disregard my previous comment. I see that your ‘Insider’s View’ reference calls out email as being an acceptable form of communication for purposes of these codes. Thanks
Hi Rick
I work in a hospital based outpatient setting. Since we bill on a UB-04 claim form under the hospital NPI, will we be able to be reimbursed for these services? We are hearing that only professional fees are being payed with these new regs, and the way we bill it is only technical fees that we are currently paid for. Thanks
We believe yes! You may want to contact your MAC if you have questions and/or concerns.
As we are not statutorily licensed to provide TeleHealth, how is this different than E-Visits?
Because there is a difference between E-Visits and telehealth services. The terms are not the same and the delivery modes are different.
E-visits are simply short term, assessments and management activities that are conducted online or via some other digital platform and include any associated clinical decision-making. Am I missing anything? It is simply answering some questions and providing some guidance for up to 7 days?
Is it known if a physician performs an e-visit in the same 7 day period as a therapist if both will get paid?
A physician would not bill the same codes that PTs, OTs and SLPs would bill for an E-Visit.
Rick:
I understand e-visits but what about out patient physical therapy and home visits, how would that work?
Here is an article I wrote last week.
https://gawendaseminars.com/coronavirus-and-therapy-in-the-home/
We are hearing from billing that e-visits are billable for locations that bill as private practice/professional billing and is not an option for locations that bill facility based. From what I am reading in your FAQ it seems that both facility and professional billing locations should be able to do e-visits. Do you have a link to any info from CMS that I can use to provide them additional info.
As you can imagine, this is a fluid process, things are changing all the time and trying to get clarification from CMS right now is slow. As we obtian updated information and/or clarification, it will be posted to my website.
Hi Rick – thanks for all of this great info. So, if we are able to actually bill for telehealth services, do we use our normal CPT codes? Someone sent me 3 codes 99213, 99214, 99215. They appear to be MD eval and management codes. Then someone else sent me 98966, 98967, 98968. Those appear to be about the same as e-visit HCPS MC G codes (G2061, G2062, G2063). Just looking for some clarification. Please don’t tell me I have to call each Ins company, because that is a nearly impossible feat these days. Thanks again. Cheers!
If an insurance carrier pays for telehealth for PT, OT and SLP, you would need to contact each one to see what CPT codes to use and what modifiers, if any, are required.
Can therapists perform e-visits from there home or do they have to be in the physical office they normally see patients from
From their home, if applicable.
Hi Rick. Sorry if I missed it, but do Medicare Advantage plans have to pay for the e-visit codes since CMS said Medicare is paying for them?
Yes
Rick, I am looking for clarification on whether hospital based outpatient physical therapists can bill medicare for e-visits.
It is our belief that the answer is yes since CMS tells institutional providers to use condition code DR, but we are awaiting clarification from CMS.
Any update on hospital based outpatient therapy (billing on UB04) being able to bill new CPT codes for e-visit?
When CMS issues any clarification, it will be posted on my website.
Where do we find the information on payment localities, to determine what payment to expect in our locality? We are in AZ.
Thank you!
You can find the fee schedule either on the CMS website as well as your Medicare contractors website.
In a situation where patient is being seen for multiple disciplines (PT, OT, & SLP) would the cumulative amount of minutes be across all disciplines or just across the revenue codes?
Yes, but keep in mind we think that the G2061, G2062 and G2063 can only be billed by private practices. We are seeking further clarification from CMS ion this and several other questions.
Just to clarify, you are saying yes that it is cumulative across all disciplines and does not take into account the revenue code? We understand that these codes may not be payable by CMS but we are looking into it from a commercial insurance standpoint.
By discipline
If a Medicare patient’s POC has expired, can we do a non-charge update to it not in person (phone or patient portal) and then do an e-visit under the updated POC?
We are not sure if a current POC is required in order to do an E-Visit.
I keep receiving denials for G2062 and my local MAC is telling me very different answers. I am physical therapist, so I know I must have modifier GP included along with CR, which order do the modifiers need to be in?
My opinion only is the MACs have not updated their billing software yet to accept these codes from PTs, OTs and SLPs.
Our office is continuing to have the same issues. All of the evisit codes are being denied. Upon investigation, they are also telling us that PT’s are not allowed to bill these services. I’d hate to continue to deliver these services and in the end they deny all of them. Any insight?
Do E-visits or telephonic visits count toward the 10 visit Progress Note Requirement for Medicare patients?
How would we handle a patient’s POC expiring when they are unable to come in for a face to face visit? Are E-visits or telphone visits allowed when the patient’s POC has expired?
Thank you so much for all of the great information!
No they don’t.
Can we see and bill for a patient 2x as week, take there patient initiated concern contact on a day we did not physically see or treat them, bill for the evisit, and continue seeing and billing the patient 2x a week for routine CPT codes? Example: 3/30 pt seen for 2 units 97110, 3/31 patient called with concern/discussed how we will address next visit, docu and billed G2061, 4/2 pt seen for 97112 and 97110.
My opinion is if a patient is still coming in to see you for therapy visits, then I would question the need for an E-Visit.