12/04/2018

ASK MSHO

December 2018, Frequently Asked Questions

Question: I heard that Medicare approved and will pay for a new code that allows a doctor to talk on the phone with the patient to evaluate them!  Is this true?  Do you have any information about it?

Answer: It's true!  There is a new code approved by Medicare in the Physician Fee Schedule Final Rule for 2019.  

• G2012 is described as: “Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.”

Question: For the new G2012 Virtual Check-in Service - Is there a patient co-pay and do we need consent from the patient?

Answer:  Yes, the new code, G0212, falls under the physician fee schedule and therefore it is subject to the 20% patient co-pay.  The reimbursement for this code is approximately $9.00 as it has been approved for .25 physician work relative value units (RVUs).

Yes, you MUST obtain consent from the patient EACH TIME this code is billed.  There is no limit on the number of times you can utilize this code for any patient.

Question: For the new virtual check in code, can the patient be new to us or is this only for established patients?  Also, can they be home and we talk to them on the phone?

Answer: The patient must be an established patient.  Yes, it can be a phone call but, if the patient had an office visit within the past 7 days OR the call results in a scheduled office visit within the next 24 hours or "next available appointment", then you cannot bill for this service.  It would be included in the E/M visit.  This code is not part of Telehealth and therefore the patient does not have to be in a rural area or any specific originating site.  The patient can be home.  Lastly, "we" must be the provider. Cinical or ancillary staff (nurses, etc) cannot bill for this service, even under "incident to".

Question: I heard about the new virtual check in code, but what if the patient just sends us a picture?  Can we bill for review of that?

Answer: Yes!  There is another new code this year, Remote Evaluation of Video or Image G2010.  

• “Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment”.

This allows a patient to send the physician a photo or video for the physician to decide if an office visit is necessary.

• As an example, if a patient sends their physician a photo of a rash and the physician makes a diagnosis and directs treatment for the rash without the patient actually coming in to be seen.

Like the virtual check in code, patient co-pay applies and must have consent from the patient.  The reimbursement is set at 0.18 RVUs (approx. $6.50)

Question: I know CMS proposed to reduce payment for services when we use Modifier 25.  Do you know if this became final?

Answer: No!  Thank goodness!  This had potential to reduce the administration code payment(s) when an office visit was billed the same day with modifier 25.  This was NOT finalized in the Rule.

Question:  In the 2019 Final Rule, can you update us on the E & M changes?

Answer: The 2019 Physician Fee Schedule Final Rule did include some changes for 2019, but many of the proposed changes were delayed or not implemented at all. Keep in mind that these changes apply to Medicare only and not private payers. Documentation changes apply to new and established patient visits in the office and outpatient hospital settings. They do not apply to hospital visits or other E/M services.

Not finalized….

• Modifier 25 Reduction

• CMS did not finalize multiple procedure payment reduction for modifier -25. The proposal was to pay at 50% the lowest valued procedure when two procedures were reported and modifier 25 was on the claim.
• CMS did not finalize a proposal that would allow two visits by physicians of the same specialty in one calendar day.

Finalized….

• The billing provider does not have to personally document the chief complaint or the HPI. Ancillary staff may record this, or it could be recorded on a form by the patient. The billing provider must note that it was reviewed and verified in the medical record on the day of the visit.
• For established patients, the provider does not need to re-enter information already in the record, as long as it is noted as reviewed and unchanged, or reviewed and updated. The provider may choose to focus on what has changed since the last visit, or on pertinent items that have not changed and need not re-record the required elements. The practitioner should still review prior data, update if needed and indicate that this was done.
• For home visits, the medical necessity for the home visit does not need to be stated in the note.
• There is a new code for chronic care management performed by the physician, NP or PA, 99491, and CMS is making this a payable code. 
• There are new codes for a brief, virtual check-in (G2012) and for the provider looking at a pre-recorded image or video, “store and forward” (G2010).
• These codes are used to determine if a visit might be needed.
• The RVUs are low.
• These codes cannot be used if they are a result of an office visit in the past 7 days or result in an office visit in the next 24 hours, or next available appointment.
• These codes cannot be utilized by ancillary staff (nurses, etc).

Finalized but postponed until 2021….

• CMS is not implementing a single payment and single RVU value for levels 2-5 E/M codes.

• They say they will implement a changed version in 2021, which would pay a single payment rate for level one patients, a single payment rate for levels 2-4 and a single payment rate for level 5 visits. (Varied by new or established patients).
• They did note that the AMA is working on changes, so keep an eye out for that as well.

• The two add-on codes for primary care and selected specialty services.

• CMS has developed the code description for these, and valued them, but is not implementing these until 2021.
• CMS changed the valuation of these two codes to be the same, rather than having a lower value for the primary care service.

• The new prolonged services HCPCS code (30 minutes) is postponed until 2021.