A Little More Time
According to JDSupra and other news outlets, the Act extends a variety of federal healthcare programs, including the so-called “telehealth flexibilities” from the public health emergency (PHE) era that were set to expire on December 31, 2024. But these extensions will be quite ephemeral. Pursuant to the Act, the Medicare telehealth flexibilities will be available only through March 31, 2025. Here are a few of the Act’s short-term provisions:
- Removing geographic requirements and expanding originating sites for telehealth services [42 USC § 1395m(m)]
- Telehealth services can be delivered to any location in the U.S., including the home of an individual.
- Expanding practitioners eligible to furnish telehealth services [42 USC § 1395m(m)(4)(E)]
- In addition to physicians, the following types of practitioners are eligible to furnish telehealth services: physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists, certified nurse-midwifes, clinical social workers, clinical psychologists, registered dietitians or nutrition professionals, qualified occupational therapists, qualified physical therapists, qualified speech-language pathologists, and qualified audiologists.
- Allowing for the furnishing of audio-only telehealth services [42 USC 1395m(m)(9)]
- Audio-only telehealth services are covered and reimbursable.
While these extensions will no doubt be welcomed by telehealth providers and patients across the nation, they are pared down from the broader protections contained in earlier versions of the Act. For example, Congress had negotiated a funding bill that would have extended telehealth flexibilities through December 31, 2026, but support for this iteration of the bill faltered. According to observers within the healthcare sector, telehealth flexibilities enjoy broad bipartisan support in Congress, and many expect them to be made permanent or extended again prior to their March 31 expiration.
Coding Quirks
According to the Centers for Medicare and Medicaid Services (CMS), Medicare will not be utilizing the new codes created within the audio-video code set. Providers are instead expected to continue to utilize the evaluation and management (E/M) codes for these telehealth services, as if they were conducted face to face.
When coding telehealth visits through March 31, 2025, here are some things to remember:
- According to updates for 2025, audio-only telehealth visits should be coded using the new CPT codes 98008-98015 for both new and established patients (see below code list), replacing the old telephone-only codes 99441-99443, which are being deleted.
- These new codes specifically designate audio-only telehealth encounters and should be utilized when a patient is unable or unwilling to use video technology while the provider can access such technology.
98008
Synchronous audio-only visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination, straightforward medical decision making, and more than 10 minutes of medical discussion.
When using total time on the date of the encounter for code selection, 15 minutes must be met or exceeded.
98009
Synchronous audio-only visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination, low medical decision making, and more than 10 minutes of medical discussion.
When using total time on the date of the encounter for code selection, 30 minutes must be met or exceeded.
98010
Synchronous audio-only visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination, moderate medical decision making, and more than 10 minutes of medical discussion.
When using total time on the date of the encounter for code selection, 45 minutes must be met or exceeded.
98011
Synchronous audio-only visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination, high medical decision making, and more than 10 minutes of medical discussion.
When using total time on the date of the encounter for code selection, 60 minutes must be met or exceeded.
98012
Synchronous audio-only visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination, straightforward medical decision making, and more than 10 minutes of medical discussion.
When using total time on the date of the encounter for code selection, 10 minutes must be exceeded.
98013
Synchronous audio-only visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination, low medical decision making, and more than 10 minutes of medical discussion.
When using total time on the date of the encounter for code selection, 20 minutes must be exceeded.
98014
Synchronous audio-only visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination, moderate medical decision making, and more than 10 minutes of medical discussion.
When using total time on the date of the encounter for code selection, 30 minutes must be exceeded.
98015
Synchronous audio-only visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination, high medical decision making, and more than 10 minutes of medical discussion.
When using total time on the date of the encounter for code selection, 40 minutes must be exceeded.
Again, an audio-video telehealth visit will be coded the same as it currently is with codes 99202-99215, based on (a) new or established visit, and (b) time or medical decision-making (MDM). If you have further questions about the new telehealth flexibilities and coding requirements, please contact your account executive.