In my previous article in June, 2022, we plowed through the billing and coding updates regarding critical care services, and, I hope that it helped our readers get more acquainted with the nuances of billing and coding in the ICU. In this piece, I would like to briefly elucidate three other areas of practice, which will be relevant to all physicians across various specialties.
Dr. Humayun Anjum
Telehealth services
(PHE). Initially, the plan was to remove these from the list of covered services by the latter end of the COVID-19 PHE, which, created some uncertainty, or by December 31, 2021. Fortunately, CMS finalized that they will extend it through the end of the calendar year (CY) 2023. So, now all the telehealth services will remain on the CMS list until December 31, 2023. The general principle behind this ruling is to allow for more time for CMS and stakeholders to gather data and to submit support for requesting these services to be permanently added to the Medicare telehealth services list.
Not only has CMS extended the deadline for telehealth services but also they have gone far and beyond to extend some of the codes for cardiac and intensive cardiac rehabilitation until December 31, 2023, as well.
There has been a lot of debate regarding the geographic restrictions when it comes to telehealth visits for diagnosis, evaluation, or treatment of a mental health disorder. As per the latest Consolidated Appropriations Act of 2021 (Section 123), the home of the patient is a permissible site. But, the caveat is that there must be an in-person service with the practitioner/physician within 6 months prior to the initial telehealth visit. Additionally, there has to be a set frequency for subsequent in-person visits. And, usually the subsequent visits will need to be provided at least every 12 months. These requirements are not set in stone and can be changed on a case-by-case basis provided there is appropriate documentation in the chart.
Lastly, it is important to understand and use the appropriate telecommunication systems for the telehealth visits and the modifiers that are associated with them. By definition, it has to be audio and video equipment that allows two-way, real-time interactive communication between the patient and the provider when used for telehealth services for the diagnosis, evaluation, or treatment of mental health disorders. But, CMS is in the process of amending it to include audio-only communications technology. At this time, the use of audio-only interactive telecommunications system is limited to practitioners who have the capability to provide two-way audio/video communications but, where the patient is not capable, or does not consent to, the use of two-way audio/video technology. Modifier FQ should be attached to all the mental health services that were furnished using audio-only communications. And, mental health services can include services for treatment of substance use disorders (SUD). Please do not confuse modifier FQ with modifier 93 as FQ is only for behavioral health services. And, remember that the totality of the communication of information exchanged between the provider and the patient during the course of the synchronous telemedicine service (rendered via telephone or other real-time interactive audio only telecommunication system) must be of an amount and nature that is sufficient to meet the key components and/or requirements of the same service when rendered via a face-to-face interaction.