What about telehealth billing? Answers to Your Questions About Billable Telehealth Services and Telehealth CPT Codes during COVID

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Telehealth billing practices have been challenged and telehealth CPT codes have been turned on their heads during COVID. Changes have been fast and furious, but are finally starting to stabilize, at least temporarily. Now, some of the COVID-19 temporary telehealth billing changes seem likely to become permanent. Only time will tell how it will settle, but meanwhile, Telehealth.org offers you current answers to some of the most common questions that behavioral health providers have raised about telehealth billing services and reimbursement connected with COVID.

What effect did COVID-19 have on telehealth billing and telehealth CPT codes?

Before the COVID-19 emergency, reimbursable telehealth was controlled by three parties: state-based third-party payers, state-based Medicaid programs and the federally managed Medicare. Each state and program had its own rules, with some states being more permissive than others. Some insurers offered more progressive plans than others within a single state. Medicare has been the most restrictive by only allowing telehealth services to quality for telehealth billing and reimbursement in under-served areas, such as rural locations. Medicare also limited the types of providers who were able to apply for telehealth reimbursement.

Part of the response of state insurance commissioners, state-based hospital associations, and state regulatory boards as well as the Centers for Medicare and Medicaid Services Administration (CMS) at the federal level in response to stay-at-home directives and hospital closures has been to lift this restriction while the public emergency is in effect.

Which kinds of behavioral telehealth services can now be reimbursed?

Telebehavioral health practitioners can now receive reimbursement for many telehealth billing services, including individual, couples, group and family therapy, virtual check-ins, screening exams, issuing prescriptions, and remote patient monitoring.

What are some of the behavioral health CPT Codes that I can use for reimbursement?

Here are some of the behavioral telehealth services that are reimbursable by most payers:

Is telehealth group therapy reimbursable?

Medicare guidelines include two codes for group therapy treatment, as outlined below. Most other payers will also pay for group therapy, but you most certainly don’t want to be caught without payment because you didn’t check. Whether you get paid or not, you may want to consider some of the special issues that can arise in telehealth group therapy. See COVID-19 Telehealth Group Therapy and HIPAA Privacy for details. 

Do I need to be in my office to receive reimbursement for a telehealth visit?

It depends on the payor. Behavioral health practitioners working with Medicare beneficiaries can conduct telehealth billing services from any location, for any patient wherever that patient is. This freedom applies to new and current Medicare patients. However, if you are serving a client or patient who has insurance with a Medicaid or third party carrier, you would be wise to double-check with the carrier first. If your third-party payer requires you to work from an office, contact your state’s Insurance Commissioner to see what can be done to continue your telehealth reimbursements flowing.

What are “eVisits” and are they reimbursable?

eVisits are usually patient-initiated digital communications that are delivered by a qualified healthcare professional for the delivery of assessment and/or management services. eVisit services include initial inquiry reviews, patient record reviews, clinical staff interactions if required, and preparing patient management plans.
Qualified patient management planning and telehealth billing services for established patients are reimbursable depending on the amount of time required during a seven-day period:

Are audio-only telehealth (telephone) services reimbursable?

Telehealth audio-only (telephone) patient calls are currently reimbursable under Medicare and Medicaid and are billable at the same rate as in-office visits or visual telehealth sessions. CMS has also increased payments for audio-only telehealth visits to match payments for similar visits in office and outpatient settings. Most states have followed suit, but some have not. For other considerations related to telephone therapy, see Telehealth.org’s article: COVID-19 Reimbursement for Telephone Telehealth?

Is my time spent providing telehealth services billable?

Yes. Billable telehealth services are billable at the normal facility rate. Office-based practitioners can use their normal POS code for non-facility rate reimbursement. Note, though, that in some states commercial insurer conditions or restrictions may apply.

Are the emergency reimbursement changes going to be permanent?

Healthcare providers, government agencies, and patients have all recognized the advantages of increased use of telehealth, including in behavioral health. More recently legislators in the U.S. House of Representatives and the U.S. Senate have conducted hearings into the post-COVID-19 health environment and are proposing legislation that will not only support the continuance of more telehealth reimbursement opportunities but also expand telehealth billing services to reach more patients in underprivileged populations. In short, it seems likely that many of the current emergency reimbursement measures will become permanent.

How do I bill for providing telehealth services?

Medicare telehealth services practitioners use is “02” if the telehealth service is delivered anywhere except for the patient’s home. If the patient is in their home, use “10”. For telehealth, the “95” modifier code is used as well. For details, see the CMS documents, titled, Place of Service Codes for Professional Claims Database (updated September 2021).

Which special forms or procedures do I need to claim reimbursement?

The Center for Connected Health Policy keeps track of state actions and requirements related to COVID-19, such as specific informed consent forms. For behavioral practitioners, an additional source of state information is maintained by the Counseling and Mental Health Center of the University of Texas at Austin.

For more information on telehealth billing and behavioral health reimbursement that has come in the wake of the COVID-19 public health emergency, be sure to check our blog post from May 2, 2020, “COVID-19 Telehealth Reimbursement Update.”

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