APA calls for comprehensive telehealth coverage

APA strongly believes that providing the best patient care during the COVID-19 health crisis requires universal coverage for telepsychology services. Here is a list of telehealth services and reimbursement codes that APA is advocating for — and that other psychologists can refer to whenever the opportunity arises for advocacy at the state and federal levels.

While telehealth is not new to health care, it has been largely inaccessible to many patient populations, and many payers did not cover all telepsychology services. Medicare, for example, previously restricted telehealth use to patients living in rural areas who traveled to designated locations known as originating sites.

To ensure that psychologists can continue to provide clinical services without putting themselves or their patients at risk during the COVID-19 public health emergency, APA is advocating that Medicare, Medicaid and private payers reimburse the full range of psychological services via telehealth using the following code sets:

• Adaptive Behavior Assessment and Treatment services
• Developmental / Behavioral Screening and Testing services
• Health behavior assessment and intervention (HBAI) codes
• Psychotherapy codes (including group psychotherapy)
• Psychological and neuropsychological testing codes

To maximize patient access to available psychological resources, APA urges Medicare, Medicaid and private payers to:

• Cover audio-only telephone services when traditional telehealth services cannot be provided.
• Waive any restrictions from plans that only allow telehealth through a telehealth carve out network (such as MDLive, Teladoc) so that any psychologist in the plan’s regular network can provide telehealth services. Plans that provide out-of-network coverage should also allow out-of-network psychologists to provide these services.
• Mitigate the need for telephone-only services by investing in an online audiovisual system (e.g., the professional version of Zoom or Doxy.me) that could be made available to their providers.
• Allow psychologists to waive co-pays and deductibles for telehealth in cases where the patient does not have the financial means to pay the difference.
• Ensure telehealth services are reimbursed for the same amount as face-to-face services (as Medicare does).
• Allow psychologists to provide clinical services via telehealth from their homes.
• Allow delivery of services to patients in their homes or wherever the patients may be located during this crisis.
• Allow access to services via telehealth and telephone for both new and existing patients.

During times of crisis, psychologists are increasingly called upon to provide vital clinical services in flexible but effective ways. That’s why APA is requesting that Medicare, Medicaid and private payers provide the following additional coverage:

• Reimbursement for psychologists for specific non-face-to-face services conducted through electronic health record portal messages or other HIPAA-compliant, secure platforms using online assessment services (CPT codes G2061–G2063):

○ G2061: Qualified nonphysician health-care professional online assessment, for an established patient, for up to seven days, cumulative time during the seven days; 5 to 10 minutes.

○ G2062: Qualified nonphysician health-care professional online assessment service, for an established patient, for up to seven days, cumulative time during the seven days; 11 to 20 minutes.

○ G2063: Qualified nonphysician health-care professional assessment service, for an established patient, for up to seven days, cumulative time during the seven days; 21 or more minutes.

• Reimbursement for psychologists’ time spent in consultation with interdisciplinary health-care teams using interprofessional telephone/internet/electronic health record assessment and management service (CPT codes 99446–99449):

○ 99446: Interprofessional telephone/internet/electronic health record assessment and management service provided by a consultative physician, including a verbal and written report to the patient's treating/requesting physician or other qualified health care professional; 5 to 10 minutes of medical consultative discussion and review.

○ 99447: Interprofessional telephone/internet/electronic health record assessment and management service provided by a consultative physician, including a verbal and written report to the patient's treating/requesting physician or other qualified health care professional; 11 to 20 minutes of medical consultative discussion and review.

○ 99448: Interprofessional telephone/internet/electronic health record assessment and management service provided by a consultative physician, including a verbal and written report to the patient's treating/requesting physician or other qualified health care professional; 21 to 30 minutes of medical consultative discussion and review.

○ 99449: Interprofessional telephone/internet/electronic health record assessment and management service provided by a consultative physician, including a verbal and written report to the patient's treating/requesting physician or other qualified health care professional; 31 minutes or more of medical consultative discussion and review.

• Reimbursement for psychologists’ use of telephone assessment and management services (CPT codes 98966–98968)

○ 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 seven days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 5 to 10 minutes of medical discussion.

○ 98967: 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 seven days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 11 to 20 minutes of medical discussion.

○ 98968: 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 seven days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 21 to 30 minutes of medical discussion.