The final Medicare 2019 Physician Fee Schedule https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched/index.html rule was posted on November 1, 2019, to be effective January 1, 2019.  It includes Section II(D) entitled “Modernizing Medicare Physician Payment by Recognizing Communication Technology-Based Services”, with several subsections.

1. Brief communication technology-based services (EG Virtual Check-In) (HCPCS Code G2012)
2. Remote evaluation of prerecorded patient information (HCPCS Code G2010)
3. Interprofessional Internet Consultations (CPT Codes 99451, 99452, 99446, 99447, 99448 and 99449)
4. Additional Medicare Telehealth Services
5. Expanded Telehealth Home Dialysis
6. Telehealth Substance Abuse Disorder Prevention and Treatment

This post will be devoted to the Communication-Based Codes and Virtual Check-In.  CMS has proposed to allow certain “modernized” services, as distinguished from the traditional established Medicare Telehealth rules which have specific technology and location requirements.

Starting January 1, 2019, Physicians or NPPs who are authorized to bill for E/M services may report time-based codes for services to existing patients for specified consults and referrals that do not involve or require a face-to-face patient encounter.  These are identified as interprofessional “telephone/internet/electronic” health record assessment and health management services provided by a consulting physician based upon time devoted, as follows:

• 99446 (5-10 minutes)
• 99447 (11-20 minutes)
• 99448 (21-30 minutes)
• 99449 (31 minutes or more)

 These services include verbal or written reports to other physicians or qualified health care professionals treating the patient.  Furthermore, CPT codes 99451 and 99452 include time devoted to preparing written reports.

CMS has also introduced two codes for non-face-to-face evaluations of patients used to determine whether the patient requires an office visit (i.e. a Virtual Check-In).

• G2010 (Remote evaluation of recorded video and/or images submitted by an established patient [e.g., store and forward], including interpretation with follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment).
• G2012 (Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 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).