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ACS COVID-19 Telehealth Resources

The use of telehealth and other virtual services is critical to reducing exposure to Coronavirus Disease 2019 (COVID-19) and ensuring continuity of care for individuals with chronic conditions during this public health emergency (PHE). The American College of Surgeons (ACS) has created resources to help surgeons navigate and integrate virtual services into their practices and enhance their ability to safely care for patients during the COVID-19 pandemic. Contact regualtory@facs.org with questions.

Medicare Coding for Virtual Services during the PHE

What virtual services are covered by Medicare?

Download a list of covered telehealth services during the PHE

How is the type of service determined?

Changes to Medicare Telehealth Rules during the PHE

On March 30, 2020, the Centers for Medicare & Medicaid Services (CMS) revised, on an interim basis, requirements for the use of telehealth during the COVID-19 national public health emergency (PHE), which are retroactively effective March 1, 2020. The PHE declaration—which was renewed for an additional 90 days effective as of July 25—extends until October 23, or unless earlier terminated or renewed again by the U.S. Department of Health and Human Services (HHS). The table below highlights the temporary changes to telehealth rules under the Medicare Physician Fee Schedule during the COVID-19 PHE.

Rules Prior to the COVID-19 PHE

Temporary Changes During the COVID-19 PHE

What services are payable when furnished via telehealth? Payable telehealth services are limited to those included on CMS’ Covered Telehealth Services list. CMS expanded its list of services eligible for telehealth coverage to include emergency department visits, initial nursing facility and discharge visits, home visits, therapy services, and others. See CMS’ updated Covered Telehealth Services List for all services payable during the PHE.
Which patients are eligible? Certain telehealth services require an established relationship between the physician and provider in order for such services to be covered under Medicare. Both new and established patients are eligible for telehealth services. CMS will not conduct audits to ensure that a prior physician/patient relationship existed for claims submitted during the PHE.
What site-of-service rules apply to telehealth? Patients must live in a rural/underserved area and receive telehealth services at a physician office or other qualified originating site. Geographic and originating site requirements are waived during the PHE. All Medicare beneficiaries are eligible to receive telehealth services regardless of where they live or the site at which the services are furnished.
What modalities can be used to furnish telehealth services? Telehealth must be provided as two-way, real time audio/visual communication. Telehealth must still be provided as two-way, real time audio/visual communication.
What HIPAA requirements apply to telehealth? Telehealth must be provided via a HIPAA-compliant platform. HIPAA compliance is waived for telehealth platforms, and physicians may use non-public-facing products, such as Apple FaceTime and Skype, to communicate with patients.
What is the cost to patients? Medicare beneficiary cost-sharing obligations (i.e., coinsurance and deductibles) apply. Medicare beneficiary cost-sharing obligations still apply. However, physicians may choose to reduce or waive any cost-sharing for telehealth services, which will not be considered an inducement or as likely to influence future referrals by the Office of the Inspector General (OIG). CMS has waived cost-sharing for COVID-19 testing-related services, and physicians should not charge Medicare patients any co-insurance and/or deductible amounts for those services.
How should telehealth services be reported? Claims for Medicare telehealth services should include place of service (POS) code 02, which is specific to telehealth services. Claims for Medicare telehealth services should include the POS code that would have been reported had the service been furnished in person. Modifier 95 should be appended to claim lines that describe services furnished via telehealth. Modifier 95 and Modifier CS should both be appended when COVID-19 testing-related services are furnished via a telehealth E/M visit. The CS modifier is used to identify the service as subject to the cost-sharing wavier for COVID-19 testing-related services and indicates that the claim should be reimbursed at 100%, including the amount that would have been paid by the patient.