On March 17, 2020, the Trump administration announced an expansion of Medicare coverage for virtual health services. The Medicare expansion is intended to make medical offices more available to people who need to be seen in-person and to mitigate the spread of the novel Coronavirus. Medicare can now pay for office, hospital, and other visits furnished via virtual services across the country, including a patient’s place of residence, starting March 6, 2020. Before this waiver came into effect, Medicare could only pay for virtual health services received by a person who lives in a designated rural area who is present in a clinic, hospital, or certain other types of medical facilities for the service. The waiver allows coverage for three types of virtual services physicians and other professionals can provide to Medicare beneficiaries: Medicare telehealth visits, virtual check-ins, and e-visits. It is important to note these services need not be limited to Coronavirus-related treatment to be covered by Medicare.
 
Medicare telehealth visits are described as a visit that uses telecommunications systems between a provider and a patient. Qualified providers permitted to furnish Medicare telehealth visits include physicians and certain non-physician practitioners such as nurse practitioners, physician assistants, and certified nurse midwives. Other practitioners, such as certified nurse anesthetists, licensed clinical social workers, clinical psychologists, and registered dietitians or nutrition professionals may also furnish these services. To qualify as a Medicare telehealth visit, the provider must use an interactive audio and video telecommunications system that permits real-time communication between the distant site and the patient at home. These visits are considered the same as in-person visits and are paid at the same rate as regular, in-person visits. The Medicare coinsurance and deductible would generally apply to these services. However, the Department of Health and Human Services ("HHS") Office of Inspector General is providing flexibility for health care providers to reduce or waive cost-sharing for telehealth visits paid by federal health care programs. Additionally, to the extent the waiver requires an established relationship, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency. Common billing codes for Medicare telehealth visits are 99201-99215 (office or other outpatient visits) and G0425-G0427 (telehealth consultations, emergency department, or initial inpatient). A full list of payable telehealth services, as well as the billing codes for such services, can be found here.
 
Virtual check-ins are described as a brief (5-10 minutes) check-in with a practitioner via telephone or other telecommunications device to decide whether an office visit or other service is needed. Additionally, a remote evaluation of recorded video and/or images submitted by a patient are covered as virtual check-ins. Unlike medical telehealth visits, virtual check-ins can only be reported when a patient has an established relationship with the billing practice. Also unlike medical telehealth visits, which require audio and visual capabilities for real time communication, virtual check-ins can be conducted over a broader range of communication methods such as secure text messaging, email, or use of a patient portal. While practitioners may educate beneficiaries on the availability of virtual check-ins, the patient must verbally consent to receive virtual check-in services. As far as billing codes for virtual check-ins, HCPCS code G2012 covers brief communication technology-based services, such as services by telephone. Services related to video or images captured by a patient and sent to a physician for evaluation are covered by HCPCS code G2010.
 
E-visits are described as communications between a patient and their provider through an online patient portal. Importantly, there are no geographic or location restrictions for e-visits. Like virtual check-ins, e-visit services can only be reported when a patient has an established relationship with the billing practice. For e-visits, the patient must generate the initial inquiry and communications can occur over a seven-day period. The patient must also verbally consent to receive e-visit services, but practitioners may educate beneficiaries on the availability of the service prior to patient initiation. The Medicare coinsurance and deductible would apply to these services. Practitioners who may independently bill Medicare for evaluation and management visits (for instance, physicians and nurse practitioners) can bill the following codes:

• 99421: Online digital evaluation and management service, for an established patient, for up to seven days, cumulative time during the seven days; 5–10 minutes;
• 99422: Online digital evaluation and management service, for an established patient, for up to seven days cumulative time during the seven days; 11– 20 minutes;
• 99423: Online digital evaluation and management service, for an established patient, for up to seven days, cumulative time during the seven days; 21 or more minutes.

 
Clinicians who may not independently bill for evaluation and management visits (for example – physical therapists, occupational therapists, speech language pathologists, clinical psychologists) can also provide these e-visits and bill the following codes:

• G2061: Qualified non-physician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the seven days; 5–10 minutes;
• G2062: Qualified non-physician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the seven days; 11–20 minutes
• G2063: Qualified non-physician qualified healthcare professional assessment and management service, for an established patient, for up to seven days, cumulative time during the seven days; 21 or more minutes.

 
The General Provider Telehealth and Telemedicine Took Kit, found here, provides several helpful resources related to telehealth, including basic information on setting up telehealth technologies.
 
The recent government actions and economic standstill resulting from the spread of COVID-19 present uncharted waters for many industries in the United States. Spilman's COVID-19 Task Force and the Health Care Practice Group are well equipped to help you navigate those waters and provide the best possible care to your patients. Please contact us with any questions you have regarding Medicare coverage of virtual healthcare services.