Commentary
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Author(s):
"For telephone-only (audio only) visits, Medicare has officially stated that such a visit would be considered the same as an in-person visit, with a few qualifications," write Jonathan Rubenstein, MD, and Mark Painter.
Jonathan Rubenstein, MD
You are not alone in your confusion. You are correct that Congress extended Medicare coverage of telehealth until March 31, 2025. This temporary “fix” simply extended the current Public Health Emergency (PHE) guidelines that allowed Medicare coverage for telehealth during and since the COVID-19 pandemic.
You are also correct that the American Medical Association deleted codes 99441 to 99443 from the Current Procedural Terminology coding system and added new codes for telehealth and telephone (audio only) evaluation and management (E/M) visits, effective January 1, 2025.
You may recall that in our December 2024 article covering the final rule for 2025, we addressed Medicare’s plan to handle this coding issue.1 Here, we provide a quick recap of the rules as they apply for Medicare:
First, the rules and coding for telehealth visits (audio and visual connection) remain the same as they were in 2024. Report these visits with an appropriate place of service (POS) code; for the patient at home during the encounter, use POS 10. Report the appropriate E/M code based on documentation using total E/M time or Medical Decision-Making (MDM). Modifier -95 can be appended and may be required by some Medicare administrative contractors and other payers, but it should not be necessary with POS 10; however, not all computer systems are set up to recognize this appropriately.
Mark Painter
For telephone-only (audio only) visits, Medicare has officially stated that such a visit would be considered the same as an in-person visit, with a few qualifications. According to Medicare, after January 1, 2025, audio visits would be reported with an appropriate POS code (again 10 if the patient is at home for the service) with a modifier -93 appended to the appropriate E/M code. Documentation would need to support the code reported based on either total E/M time or MDM. This is a change from last year. Medicare did place some qualifications on reporting telephone-only visits, and we present a summary below.
1. The patient must be offered or scheduled for a telehealth (audio-visual) visit. Your office and the qualified health professional providing services to the patient must be able to participate in an audio-visual health care visit via a method compliant with the Health Insurance Portability and Accountability Act. If the patient requests an audio-only visit or cannot participate in the video portion during a scheduled audio-visual visit, the visit may be conducted through an audio-only platform.
A. Document the patient’s location, patient consent to treat, understanding of co-pay or deductible payment, and method of visit––audio or audio-visual.
B. Documentation of the clinical encounter will be used to select the visit code based on MDM or total E/M time using the same rules as in-person or audio-visual visits.
C. Use E/M Office or Other Outpatient code with modifier -93 with the appropriate POS code.
Private payers may require codes 98001 to 98015 for the reporting of telehealth services for commercial insurance contracts. Medicare Advantage plans will likely follow Medicare but may require the use of these new codes. Your office should check with each plan to determine the appropriate reporting pathway for 2025 claims.
Code 98016 (brief communication technology–based service [eg, virtual check-in] by a physician or other qualified health care professional who can report E/M services provided to an established patient, not originating from a related E/M service provided within the previous 7 days or leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussionis considered an active code for Medicare) may be used to report services provided through technology services typically requested or initiated by the patient for encounters that do not lead to a follow-up E/M visit.
REFERENCE
1. Rubenstein JR, Painter M. Final rule: Conversion factor set for 2.83% reduction in 2025. Urology Times. November 27, 2024. Accessed February 24, 2025. https://tinyurl.com/2rrvuhzk
Send coding and reimbursement questions to Jonathan Rubenstein, MD, and Mark Painter c/o Urology Times®, at UTeditors@mjhlifesciences.com.
The information in this column is designed to be authoritative, and every effort has been made to ensure its accuracy at the time it was written. However, readers are encouraged to check with their individual carrier or private payers for updates and to confirm that this information conforms to their specific rules.
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