As we all know the PHE, public health emergency, ended on May 11th, 2023, but the confusion on how to report Telehealth services continues to live on. When Medicare published its Final Rule last November 2nd, 2023, they did extend many of the original flexibilities through the end of 2024. However, some definite changes will impact all medical practices engaged in using Telehealth for their encounters, and it is imperative to be up on all of the current published guidance.
CPT has also added their insight on what “qualifies” as Audio-Video and Audio-Only services with the additions of new guidance in CPT 2024 (page xvii) and Appendix P and Appendix T of the code book. Remember to check with commercial payers for their specific updates to their telehealth payer policies, so that you are not over or under-reporting your services in 2024.
POS 02 is to be used when the patient is not in their home, and the reimbursement will be linked to F (facility) rates.
POS 10 is to be used when the patient is in their home, at the time of the telehealth encounter and reimbursement rates will be the same as NF (non-facility) rates.
For example, if the physician is licensed and resides in Illinois, and the patient resides in Illinois, but the patient is in Florida on vacation and wants a telehealth visit, the physician would have to be licensed in Florida to provide the visit. Or if the physician is licensed in Illinois, but is in California on vacation, he/she would have to be licensed in California to see a patient via Telehealth.
During the PHE, we saw the need for telehealth, and how it allowed for access to medical care when we were told to stay home or to quarantine if COVID-19 symptoms were prevalent, or if you were a high-risk patient. But the payers made it too easy for providers to bill telehealth services, without any guardrails to make sure over-utilization did not occur. Unfortunately, we have seen “bad actors” taking liberties by reporting telehealth visits when not medically necessary or when not appropriate for the patient circumstance. It appears that post PHE, many visits via telehealth are for convenience, and may not be appropriate when the patient is available to come in person.
Many practices have also billed for audio only encounters to give routine test results or to refill prescriptions which is non-compliant. A reminder that if you didn’t charge for incidental and ancillary services prior to the PHE, like giving patient routine test results over the phone, it is not appropriate to report it as a telehealth visit now.
It is important to review the language in CPT® Professional Edition 2024 to know when it is appropriate to report a telehealth visit, and not use that option for incidental or non-medically necessary services. See page xvii in CPT® 2024 to get the information.
Telehealth can be an “invited risk” if not met with compliance. OIG telehealth audits have been ongoing since 2021. Make sure you are spot-checking and internally and externally auditing your telehealth services and practices for compliance to avoid a costly audit in the future.
This article was updated on January 9th, 2024
BS, CPC, CCC, CEMC, CCS, CCS-P, CMC, CMSCS, ACS-CA, SCP-CA, QMGC, QMCRC, QMPM
Ms. Terry Fletcher is a Healthcare Coding and Reimbursement Consultant, Educator and Auditor based in Southern California. With over 30-years experience, Ms. Fletcher teaches over 100 specialty coding Seminars, Teleconferences and Webinars every year. You can find her CodeCast® podcast series, focusing on Physician Coding, Billing, Reimbursement, compliance, and Medical industry revenue opportunities, on iTunes, Stitcher, TuneIn, and Google Play.
Terry is also an NAMAS Member and Podcast Host, and host of the NSCHBC Edge Podcast.