Temporary changes to federal Medicare telehealth policies

Effective March 6, 2020, psychologists and other providers who treat Medicare beneficiaries have greater flexibility to furnish telehealth services during the COVID-19 public health emergency, thanks to a new law passed by Congress.

Further changes (PDF, 400KB) were announced on March 30, 2020, and have been incorporated below.

Additional changes regarding place of service were released on April 3, 2020 and also appear below.

More changes were announced on April 30, 2020 including the allowance of most psychology services to be provided by telephone without video. These phone-only services are retroactive to March 1, 2020. Additionally, CMS added more codes to the Medicare telehealth list. These changes are incorporated below.

Under the Coronavirus Preparedness and Response Supplemental Appropriations Act 2020, the Centers for Medicare and Medicaid Services (CMS) is waiving key telehealth requirements allowing Medicare beneficiaries to receive services from their homes with fewer restrictions.

Psychologists should know that during the crisis:

• Psychologists may provide telehealth services from their home.
• Telehealth services can now be provided to both new and established Medicare patients.
• Medicare patients are no longer required to be in an originating site and can now receive telehealth services in their own homes as well as in any health-care facility.
• Telehealth is now available to Medicare beneficiaries in all parts of the country, not just in rural areas.
• Psychological and neuropsychological testing, group psychotherapy, developmental screening, and adaptive behavior assessment and treatment can be billed when provided through telehealth.
• For traditional telehealth, telephones may be used only with audio and video functions that provide two-way real-time interactive communication. On April 30, 2020, following recommendations from APA, CMS announced that many telephone only psychological services will be reimbursed. See below for the specific CPT codes.
• Visits to patients in nursing homes may be conducted via telehealth.
• Visits to inpatients and skilled nursing facility residents can be provided as needed instead of only once every 30 days.
• Telehealth services are reimbursed for the same dollar amount as in-person visits.
• Providers may reduce or waive cost-sharing for telehealth visits during this emergency period. This does not apply to brief communication e-Visits (described below).
• CMS guidance states that the Department of Health and Human Services (HHS) will exercise enforcement discretion and waive penalties for HIPAA violations against providers who serve patients in good faith through everyday communication technologies, such as FaceTime or Skype, during this public emergency.

Psychologists should bill Medicare for telehealth services the same way they bill for an office visit by using the appropriate CPT^® code for the service provided. At this time, Medicare is allowing these mental and behavioral health services to be provided via telehealth in three categories:

CPT Codes Allowed via Phone Only and Traditional Telehealth

• Diagnostic Interview (90791, 90792)
• Psychotherapy (90832, 90833, 90834, 90836, 90837, 90838)
• Psychoanalysis (90845)
• Group Psychotherapy (90853)
• Family Psychotherapy (90846, 90847)
• Crisis Intervention and Interactive Complexity (90839, 90840, 90785)
• Neurobehavioral Status Exam (96116, 96121)
• Psychological Evaluation (96130, 96131)
• Neuropsychological Evaluation (96132, 96133)
• Psychological & Neuropsychological Test Administration & Scoring ( 96136, 96137, 96138, 96139)
• Health Behavior Assessment ( 96156)
• Health Behavior Intervention, Individual (96158, 96159)
• Health Behavior Intervention, Group (96164, 96165)
• Health Behavior Intervention, Family with patient (96167, 96178)
• Behavioral Screening (96127)
• Screening, Brief Intervention, and Referral to Treatment (G0396, G0397)

CPT Codes Allowed via Traditional Telehealth Only

• Developmental Screening and Testing (96110, 96112, 96113)
• Adaptive Behavior Assessment (97151, 97152, 0362T)
• Adaptive Behavior Treatment (97153, 97154, 97155, 97156, 97157, 97158, 0373T)

CPT Codes Added to the Telehealth List but as Non-Covered Services (not reimbursable in Medicare)

• Psychophysiological therapy (90875)
• Health Behavior Intervention, Family without patient (96170, 96171)

Place of service

When providing services through telehealth or phone you should use the place of service (POS) that would have been reported if the service had been furnished in-person. CMS is making this change to identify when it is appropriate to pay a non-facility fee, rather than a facility fee which would have automatically been included under POS 02. To illustrate, a psychologist who would have seen patients in a private office should use POS 11. Those who would have treated the patient in a clinic or skilled nursing facility should use the corresponding POS.

Telehealth modifiers

All claims for traditional telehealth and audio-only telehealth services should include modifier 95.

Please note that Telephone Assessment and Management Services (98666-98668) are not considered telehealth services and, therefore, do not require modifier 95.

Psychologists can now bill for time spent on audio-only telephones if a patient calls because they are experiencing mental health issues or symptoms. During these calls, the psychologist engages in assessment of the problem (not formal testing) and then provides an intervention service.

These services, and their accompanying CPT codes, do not replace traditional psychotherapy and reimburse at a lower rate because they were built for brief and directed services.

To bill for assessment and management services, psychologists would use the following codes:

• 98966: Telephone assessment and management service provided by a qualified nonphysician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.

○ 98967: Cumulative time of 11-20 minutes of medical discussion during the seven days

○ 98968: Cumulative time o 21-30 minutes of medical discussion during the seven days

Visit the Telephone Assessment and Management Services page for more information.

Psychologists can also bill for brief communications (known as e-Visits) with established Medicare patients. E-Visits involve a brief communication, typically initiated by the patient, and can be furnished in any location or geographic area. Medicare co-insurance and deductible amounts cannot be waived for e-Visits.

To bill for an e-Visit, psychologists would use the following codes:

• G2061: Qualified nonphysician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the seven days: 5-10 minutes.

○ G2062: cumulative time of 11-20 minutes during the seven days.

○ G2063: cumulative time of 21 or more minutes during the seven days.

Visit the Online Assessment and Management Services (e-Visits) page for more information.

We will continue to keep members updated as we learn more. Government and payer policies in response to the coronavirus crisis are changing rapidly, so we recommend that you check our Practice Resource Hub frequently.