“Virtual Check-Ins:” Medicare’s New Communication Technology-Based Payable Service

New strategy holds promise for future extensions of this technology.

A medical practice can now bill and collect for a specific telehealth service without the strict rules of the originating sites being outside of a Metropolitan Statistical Area (MSA) or in a rural Health Professional Shortage Area (HSPA) located in a rural census tract. For example, the patient doesn’t have to live in a particular type of geographical area or go to an original site, such as a physician’s office or hospital.

The rules are pretty simple:

1. The patient needs to be established to the practice.
2. A total of 5-10 minutes of medical discussion must be documented.
3. “Global days” need to be documented on the front and back end of the “visit.”
4. The virtual visit cannot be related to an office visit taking place seven days before or 24 hours after.
5. The patient can call the provider from home, with place of service (POS) being listed as 11 for the physician service.
6. The physician would need to document in the record that the patient does not need to come in for a follow-up visit unless there is a problem.

Medicare introduced two new HCPCS codes to the professional service side of billing, G2012 and G2010:

• G2012 (Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified healthcare professional who can report evaluation and management (E&M) services, provided to an established patient, not originating from a related E&M service provided within the previous seven 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).
• G2010 (Remote evaluation of recorded video and/or images submitted by an established patient [store and forward], including interpretation with follow-up with the patient within 24 business hours, not originating from a related E&M service provided with the previous seven days nor leading to an E&M service or procedure within the next 24 hours or soonest available appointment).

The services are limited to established patients, as defined in the CPT® manual: the patient must have been seen by their physician (face-to-face) or NPP of the same specialty within the last three years.

These visits are going to be tough to track, since they can’t be billed when a patient contacts the practice about a related problem from a visit that took place within the past seven days – or if that contact leads to a visit in the following 24 hours (or the “next available appointment”).

Keeping track of the dates may be one of the biggest challenges for the practice, mainly because the Centers for Medicare & Medicaid Services (CMS) is vague about the definition of the “soonest available visit.” But practices should also have a plan for the following issues if they plan to offer these remote visits:

Patient Consent: The patient will need to sign a consent form when they receive a service, and this should be documented in the patient record or by way of “virtual sign-in sheet.” Alert patients that this is new, because some patients may be used to being able to call the practice for advice without being charged.

Billing Concerns: When can you bill for these services? Using a billing office point person would be my recommendation, to ensure that the service is not bundled into a previous visit (within the last seven days) or the next available appointment (or within 24 hours post-virtual contact). I would also recommend that practices hold these claims for at least 14 days (or a certain period of time) to avoid having to refund money.

Collecting the Fees: Patients need to know that Medicare does allow payment for these services, but they will have a copay. It will be hit or miss for commercial plans on coverage. Make sure the coverage is verified before charging for it. Also, practices that offer remote visits and decide to wait until the patient’s next visit to collect a copay would need to be prepared to deal with patients who may tell you they don’t remember the call and won’t pay two copays.

Example of G2012: Let’s say someone has been a patient of your family practice clinic for a couple of years, coming in for a variety of illnesses off and on during this time period. The patient had not been seen in about three months, and that visit and a visit six months before that was for a UTI (urinary tract infection) and was treated successfully with the antibiotic Cipro. The patient calls today, and says she feels another UTI coming on, and speaks to the NP under the physician’s direct supervision. The NP speaks to the patient, documents her related symptoms in her medical record, includes time of 10 minutes, and agrees to call in a script for Cipro, as requested.

(Of note: it would not be appropriate to report G2012 if the patient was told by the physician to come in at the next available appointment for follow-up).

Next up we’ll take a look at peer-to-peer consultation, non-face-to-face. Check out our next article on this topic next week.

Program Note:

Listen to Terry Fletcher report on this topic today on Talk Ten Tuesdays, 10 a.m. EDT.