ACT Questions and Answers - July 24, 2019

The following questions and answers (Q&As) are cumulative from the Part A/B Telehealth Ask the Contractor Teleconference (ACT). Some questions have been edited for clarity and answers may have been expanded to provide further details. Similar questions were combined to eliminate redundancies. If a question was specific just for that office, Noridian addressed directly with the provider. This session included Medicare program updates, pre-submitted questions, and questions posed during the event.

Q1. Are telehealth and telemedicine services identical?
A1. No. Although both telehealth and telemedicine services use technology to communicate the definition, requirements and billing are separate and distinct services.

Q2. Are telehealth and virtual visits or virtual communication the same services?
A2. No.

Q3. Which telehealth codes can be billed when the patient is at home?
A3. Home dialysis services may be provided from the patient's home and beginning July 1, 2019, the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act removes the originating site geographic conditions and adds an individual's home as a permissible originating telehealth services site for treatment of a substance use disorder or a co-occurring mental health disorder. In addition, geographic indicators had been removed (HPSA/HRSA) for support. Services performed at the patient's home would not bill the Q-code. For more information, view the CMS Telehealth Services Booklet.

Q4. What kind of telehealth technologies are allowed in Alaska?
A4. In Alaska and Hawaii only, the federal demonstration project allows the following differences:

  • Use of asynchronous "store and forward" technology is allowed
  • Providers must bill modifier GQ with distant site code (this indicates asynchronous)
  • Medical file was collected and transmitted to provider at distant site
  • Geographic location can be anywhere; rural HPSA or non-MSA does not apply

Q5. Will Rural Health Clinic (RHC) and Federally Qualified Health Clinic (FQHC) claims submitted with HCPCS codes G2012 or G2010 be paid?
A5. No. RHCs and FQHCs are required to bill for virtual communication services using G0071. These codes are not used for telehealth originating site services in RHC and FQHCs.

Q6. Can we provide telehealth services from one of our sites to another of our sites? We have an RHC about 30 miles from our other clinic sites. If a patient comes into the RHC, can the provider be at one of the clinic sites?
A6. The scenario sited is not a telehealth service. The RHC/FQHC service described must meet virtual communication requirements.

Q7. RE: Tele-radiology. Radiology has two components (technical and professional). When the professional component is performed in a different state, we did not find any guidelines on the Noridian website about enrollment requirements and "split billing" of the technical component. How should this be billed since each MAC may be in a different payment locality?
A7. Teleradiology is not synonymous with telehealth services. If the service is not being billed globally, each component must be billed to the appropriate MAC for the location and the date it was performed.  CMS Internet Only Manual (IOM), Publication 100-04, Medicare Claims Processing Manual, Chapter 13, Section 20.1 and 150 - Payment Conditions for Radiology Services

Q8. Does the Telehealth Eligibility Search Analyzer or HRSA tool apply to tele-radiology?
A8. Tele-radiology is not a telehealth service. The HRSA tool applies to telehealth services.

Q9. Can a physician of a Critical Access Hospital (CAH) Method II provide services at a distant site?
A9. Yes.

Q10. Please clarify telepresenter information and payment for telepresenter services.
A10. The only reimbursement for the originating site is the fee for the Q3014. There is no requirement for a telepresenter to be present at the originating site, unless requested by the designated provider.  

Q11. For hospital outpatient department billing, should CPT code 99453 "Remote monitoring of physiologic parameter(s) - INITIAL SETUP" be billed on a CMS-1500 with tele-med place of service (POS) 02? Or can it be billed on a UB04?                                                   
A11. Remote monitoring is not a telehealth service and remote monitoring must meet requirement for proper hospital outpatient POS 22 or 19.

Q12. When accessing telecommunication for a patient in the emergency department, can HCPCS Q3014 be used for a facility fee?
A12. Yes. The services must meet the originating site criteria.

Q13. How can non-qualified originating site providers bill for services covered under the new SUPPORT Act?
A13. The Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act or the SUPPORT for Patients and Communities Act, particularly section 2001 of the bill exempts substance-use disorder telehealth services from specified requirements, such as geographic restrictions, under Medicare. The originating site provider must be enrolled in Medicare. The law does not include non-qualified originating site providers. In order bill, providers who provide services must be enrolled must accept assignment. H.R.6 - SUPPORT for Patients and Communities Act

Q14. When a telehealth service is performed and a nurse at the originating site is performing the hands-on portion of the physical examination and reporting those findings back to the physician, does Medicare require that the nurse's name and his/her credentials documented in the note, or is it sufficient to state that the attending nurse performed the hands-on portion (under physician oversite/supervision) of the exam? If the name must be documented, is only his/her first name sufficient?
A14. If a provider is going to use a name, include his/her first/last name and credentials. There is no requirement for a medical staff member to present unless requested at the originating site. All the information will be completed at the designated site chart. There is no additional language currently required. Documentation requirements remain unchanged for all services.

Q15. Can providers bill HCPCS G0425-G0427 and CPTs 99221-99213 on the same day?
A.15 On the National Correct Coding Initiative (NCCI) tables, HCPCS G0427 is bundled to the hospital Evaluation and Management (E/M) codes with no modifier allowed to override the bundling, not allowing to bill both on the same date; however, it may be appropriate to count the work involved in the telehealth consult toward the E/M level of the CPT codes 99221-33213.

Q16. Can palliative care providers perform telehealth?
A16. Palliative care providers often work under several specialties, internal medicine, hospitalist, or hospice/palliative. MDs can certainly perform and bill for many of the eligible telehealth type of services if they met the coverage criteria.

Q17. Can a Respiratory Therapist (RT) bill telehealth services?
A17. At this time, RTs cannot bill for telehealth services.

Q18. There is no facility fee to be billed when it is direct from provider-to-home. That does not apply to HCPCS Q3014 fee, correct?
A18. That is correct. Only the professional fee is billable.

Q19. There has been conflicting information in inter-consultation codes. Are these telemedicine codes? For example: CPT 99541, non-face-to-face consultation.
A19. The CPT 99541 is not a telehealth code. It is a medical procedural code under the range - Interprofessional Telephone/Internet/Electronic Health Record Consultations.

Q20. Is it still a requirement for patients receiving End Stage Renal Disease (ESRD) services in the home or hospital-based ESRD dialysis to meet the originating site geographic requirement?
A20. When practitioners furnish monthly home dialysis ESRD-related medical evaluations, Medicare does not apply originating site geographic conditions to hospital-based and CAH-based renal dialysis centers, renal dialysis facilities, and beneficiary homes. Independent Renal Dialysis Facilities are not eligible originating sites. The patient's home is now an authorized originating site of beneficiaries with End-Stage Renal Disease (ESRD) getting home dialysis.

Q21. We have an outpatient hospital-based clinic. The physician in the clinic is the distant site provider and they are doing the consult. Can they bill a facility fee as the physician is using their office and resources? They are not a CAH Method 2. The physicians have their own practice yet work out of their own clinic; physician-run clinic, which is the designated, metropolitan site.
A21. Yes. Bill two claims but reference the designated site. One is billed on the UB-04 while the other will be on the CMS-1500 claim form or electronic equivalent.

Q22. We are an Island group clinic. Can our clinic bill for providers who are off island or located in the states, or can we only bill for the originating site? We currently have the resource for billing portable x-rays or ultrasounds but not the evaluation and readings for the remote physician?
A22. As an originating site, you may bill only the Q code for the telehealth service as well as any services performed at your clinic. The remote provider must bill their own services as the designated site.

Q23. Should a provider add telemedicine as a service provided to our enrollment application?
A23. Providing telehealth services is not an enrollment criterion. The location in which the services are being provided must meet the criteria for either the designated site or the originating site of that service. The home office location must be on an enrollment application to be deemed eligible as a designated site.

Last Updated Aug 21, 2019