Updated December 14, 2021
In response to the spread of COVID-19, the Centers for Medicare & Medicaid Services (CMS) now allows more qualified nonphysician health care professionals, including SLPs, to report communication technology-based services (CTBS), such as e-visits, virtual check-ins, and telephone assessments, for Medicare Part B (outpatient) beneficiaries. CMS has not provided guidance regarding use of these codes in hospital outpatient or other facility-based settings.
Current Procedural Terminology (CPT) and Healthcare Common Procedure Coding System (HCPCS) CTBS codes allow clinicians to report and receive payment for brief, virtual communications that require a clinical decision. Before the public health emergency (PHE), audiologists, SLPs, and most other nonphysician groups could not bill Medicare for these services. Medicare also now allows audiologists and SLPs to provide some telepractice services during the COVID-19 pandemic, but it is important to note that CTBS codes are not considered telepractice services under Medicare’s definition. Here are the key things you need to know.
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Medicare now permanently allows SLPs to report CTBS codes for virtual check-ins, e-visits, and remote assessment of recorded images or videos beyond the PHE.
CMS permanently expanded CTBS codes for virtual check-ins, e-visits, and remote assessment of recorded images or videos for SLPs and certain other nonphysician providers, effective January 1, 2021. CMS also allows SLPs to report new remote therapeutic monitoring services beginning January 1, 2022.
It's important to note that the information on this page reflects coding and documentation guidelines that have been loosened for the duration of the federal public health emergency (PHE). For example, during the PHE, CTBS codes may be reported for both new and established patients, but under normal circumstances, most CTBS codes may only be reported for established patients. In addition, CMS isn't permanently expanding use of the telephone assessment codes (98966-98968), though they are available during the PHE. Once the PHE is over, SLPs may continue to report CTBS codes under the MPFS, but must be aware of the more restrictive coding and documentation requirements for each code.
CMS confirmed that audiologists may not bill CTBS codes to the Medicare program.
ASHA reached out to CMS to determine whether audiologists may report these services for Medicare beneficiaries and strongly urged that CMS provide equal access to these codes for audiologists. However, in subsequent communications with ASHA, CMS staff confirmed that audiologists may not report these services for Medicare beneficiaries, noting that CTBS codes describe services outside of the audiology diagnostic benefit category. Check with other non-Medicare payers to determine whether they will cover CTBS codes reported by audiologists.
State Medicaid programs and commercial plans may allow audiologists and SLPs to use CTBS codes, but aren't required to.
The information on this page outlines Medicare Part B guidance and policy for individual providers during the PHE. State Medicaid agencies and commercial insurance plans have the flexibility to develop their own coverage policies for CTBS codes. Check with your non-Medicare payers to ask about coverage and payment for these services by audiologists or SLPs. Some private payers and Medicaid programs that have expanded telepractice services, which may include CTBS codes, during the COVID-19 pandemic. Unfortunately, there is inconsistency in coverage so it is best to check directly with the payer frequently to ensure policies have not changed.
The CTBS codes describe specific virtual or telephone communications that require a clinical decision and must meet specific criteria for appropriate reporting.
The CPT and HCPCS codes for CTB services represent brief communication services conducted over different types of technology to help avoid unnecessary office visits and slow the spread of COVID-19. They do not replace full evaluation and treatment services covered under the Medicare benefit and described by existing evaluation or treatment CPT codes, such as 92523 for a comprehensive speech and language evaluation. CTBS codes are limited in scope and reflect brief check-ins or consultations that require clinical decision-making. These services, by definition, are virtual and do not replace services that would normally be performed in person.
During the PHE, clinicians can use platforms that are not compliant with Health Insurance Portability and Accountability Act (HIPAA), as long as they are not public facing.
All CTB services addressed here must be medically necessary (requires clinical decision-making and is not for administrative or scheduling purposes) and provided with patient consent.
Many CTB services also require the service to be patient-initiated. Although the patient must initiate services via communication technologies, you can notify them that these services are now available and authorized by Medicare. The patient must consent to these services at least once annually. You or your administrative staff can obtain verbal consent and notify the patient of applicable co-pay and deductible costs at the same time you provide the service. Be sure to document that you received the verbal or written consent.
CMS also confirmed that these services may be provided to both new and established patients during the COVID-19 pandemic. An established patient has received services within the past three years from you or another clinician from the same specialty who works in the same group practice. Clinicians should consider state practice acts or other local laws and regulations before initiating services with new patients. Clinicians may be required to evaluate new patients before providing clinical recommendations or treatment.
E-visits were the first set of CTBS codes CMS allowed SLPs to report during the COVID-19 pandemic. They describe brief, online assessments that are reported for cumulative time spent over the course of up to 7 days.
To correctly use 98970-98972, you should:
Do not bill 98970-98972 if the e-visit:
98970-98972 are not separately billable to Medicare or the patient under these circumstances because they are bundled into the associated services.
CMS made remote evaluation of patient videos/images available to SLPs in its interim final rule, effective March 1, 2020. HCPCS G2250 allows clinicians to bill for remote review of prerecorded images and videos from the patient.
G2250: 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 evaluation and management service provided within the previous 7 days nor leading to an evaluation and management service or procedure within the next 24 hours or soonest available appointment
To correctly use G2250, you should:
Do not bill G2250 if the review of images or video:
G2250 is not separately billable to Medicare or the patient under these circumstances because it is bundled into the associated services.
Effective January 1, 2022, the new remote therapeutic monitoring (RTM) family of CPT codes will allow clinicians who cannot bill for E/M services to report remote monitoring of health conditions and adherence and response to treatment during an episode of care. The data collected should inform a patient's treatment plan during an episode of care. For more information, see 2022 CPT Code Changes for SLPs.
To correctly use 98975-98977, you should:
To correctly use 98980 and 98981, you should:
Do not report RTM services if the:
CMS made virtual check-ins by a nonphysician provider who can't report evaluation and management (E/M) services (G2251) available to SLPs in its interim final rule, effective March 1, 2020. HCPCS code G2251 describes brief communications initiated by the patient to help determine whether they need to be seen for a full evaluation or treatment service. Effective January 1, 2022, CMS implemented G2252, which describes extended virtual check-ins. However, G2252 may only be billed to Medicare by physicians or providers who can report E/M services. SLPs may not report G2252 under the Medicare benefit.
To correctly use G2251, you should:
Do not bill G2251 if the virtual check-in:
G2251 is not separately billable to Medicare or the patient under these circumstances because it is bundled into the associated services.
CMS also made telephone assessments available to SLPs in its interim final rule, effective March 1, 2020. These can be used for lengthier discussions to address more complex or emergent issues identified by the patient or caregiver or when the patient does not have access to other modes of communication technology, such as a patient portal. Although these codes represent lengthier interactions, they should not fully replace a face-to-face visit (whether in-person or via telepractice). Note that SLPs may not bill these services to Medicare once the federal PHE expires.
To correctly use 98966-98968, you should:
Do not bill 98966-98968 if the telephone discussion:
98966-98968 are not separately billable to Medicare or the patient under these circumstances because it is bundled into the associated services.
Append the modifier -GN to indicate services provided by an SLP.
CMS considers these CTBS codes as “sometimes therapy” codes for the duration of the PHE and beyond. As a result, SLPs should include the GN modifier on claims for CTBS codes. To append the GN modifier, place it in the "modifier" section of the claim, on the same line as the CTBS code.
Use the place of service (POS) code that reflects the location of the billing provider.
When entering a POS code on a claim to describe where services occurred, clinicians should use the code that reflects where you provided the service, not where the patient received the service. If a clinician provides the service from their own home, enter the POS code to reflect where you normally would have provided the service. For example, if a clinician would have provided the service from their private practice, enter POS 11 for “office”. Do not enter POS 12 for the patient’s home or the clinician's home.
Medicare Part B (outpatient) pays for these services through the Medicare Physician Fee Schedule (MPFS).
See ASHA's analysis of the MPFS for national payment rates for CTBS codes. Actual rates will vary slightly depending on your locality. CTBS codes are subject to Medicare’s 20% coinsurance payment from the patient. The MPFS does not deduct this amount, so the actual payment by Medicare is 20% less than outlined in the fee schedule. You must make reasonable efforts to collect the 20% coinsurance from the Medicare beneficiary.
ASHA provides the information on this page based on published guidance from CMS and discussions with CMS staff. Contact your local MAC for specific information and guidance related to implementation and payment for communication technology-based services.
Contact email@example.com for additional information. Monitor ASHA’s website for the latest developments related to Medicare, Medicaid, and commercial insurance coverage of telepractice services during the COVID-19 pandemic.