Use of Communication Technology-Based Services During COVID-19

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.

On this page:

CTBS Codes and Medicare Coverage
Payer Coverage
Coding Guidelines
Billing Tips
Resources

CTBS Codes and Medicare Coverage

(updated 11/11/2021)

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.

Payer Coverage

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.

Coding Guidelines

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 (CPT Codes 98970-98972)

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.

98970: Qualified nonphysician healthcare professional online digital assessment and management, for an established patient, for up to 7 days, cumulative time during the 7 days; 5–10 minutes
98971: Qualified nonphysician healthcare professional online assessment and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 11–20 minutes
98972: Qualified nonphysician qualified healthcare professional assessment and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 21 or more minutes

To correctly use 98970-98972, you should:

Ensure the service was patient-initiated.
Conduct e-visits through a patient portal. Other forms of real-time or digital communications, such as e-mails outside of a portal or text messages, are not billable with these codes. CMS provides no additional guidance regarding the definition of a patient portal. Clinicians should check with their local MACs directly to verify whether there is flexibility to provide these services without a patient portal.
Store the exchange and document the medical necessity, your clinical decision-making and recommendations, and the amount of cumulative time spent providing e-visit services to each patient.
Report an e-visit code only once per 7 consecutive days. Select the appropriate CPT code based on the cumulative time spent providing e-visit services to each patient, through a patient portal, over the course of the 7 days. Day 1 of the 7 days begins on the first date you provide an e-visit. Telephone calls do not count toward the time for e-visits.
Review ASHA’s clinical scenarios describing examples of services that could be reported with 98970-98972.

Do not bill 98970-98972 if the e-visit:

was not patient-initiated;
takes less than 5 cumulative minutes;
is related to another evaluation or treatment service provided within the last 7 days; or
leads to an evaluation or treatment service within the next 24 hours or at the next available appointment.

98970-98972 are not separately billable to Medicare or the patient under these circumstances because they are bundled into the associated services.

Remote Evaluation of Patient Videos/Images (HCPCS Code G2250)

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:

Ensure the service was patient-initiated.
Review prerecorded images or videos sent asynchronously by the patient. This code should not be reported for real-time review and discussion of images or video over an audiovisual platform.
Follow-up with the patient within 24 business hours to provide clinical recommendations based on your review and interpretation of the images or videos. Follow-up does not have to be asynchronous and can be done through other modes of communication, such as an email, phone call, or patient portal.
Store the images/videos and document medical necessity, your interpretation of the images/videos and clinical recommendations, and that follow-up occurred within the required 24 business hours.

Do not bill G2250 if the review of images or video:

was not patient-initiated;
is related to another evaluation or treatment service provided within the last 7 days; or
leads to an evaluation or treatment service within the next 24 hours or at the next available appointment.

G2250 is not separately billable to Medicare or the patient under these circumstances because it is bundled into the associated services.

Remote Therapeutic Monitoring (CPT Codes 98975-98977, 98980, and 98981)

(added 11/11/2021)

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.

98975: Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); initial set-up and patient education on use of equipment
98976: Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); device(s) supply with scheduled (eg, daily) recording(s) and/or programmed alert(s) transmission to monitor respiratory system, each 30 days
98977: Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); device(s) supply with scheduled (eg, daily) recording(s) and/or programmed alert(s) transmission to monitor musculoskeletal system, each 30 days
98980: Remote therapeutic monitoring treatment management services, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; first 20 minutes
98981: Remote therapeutic monitoring treatment management services, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; each additional 20 minutes (listed separately in addition to code for primary procedure)

To correctly use 98975-98977, you should:

Ensure the device used to monitor and collect objective data is approved by the U.S. Food and Drug Administration (FDA). Check directly with the manufacturer for a device's FDA status.
Report the initial set-up and patient education only once per episode of care. For RTM, an episode of care begins when remote monitoring of a specific condition or treatment goal is initiated and ends when the targeted data is collected and/or treatment goals are met.
Determine whether the device used is described by 98976 (respiratory system monitoring) or 98977 (musculoskeletal system monitoring). 98976 and 98977 represent the cost of supplies for specific types of monitoring systems, however, they may not apply to speech-language pathology related services. Do not report these codes for other devices or systems not described here.

To correctly use 98980 and 98981, you should:

Spend time communicating directly with the patient/caregiver. These codes require at least one interactive communcation to provide clinical feedback to the patient/caregiver based on the data collected during monitoring.
Count cumulative time spent in data review and patient/caregiver interaction in a calendar month (not each 30 days). Use these codes to count the initial and each subsequent 20-minute increment of time spent reviewing and integrating the data collected during remote monitoring to inform treatment goals; monitor the patient’s progress and adherence to the treatment plan; and interact with the patient/caregiver. Report the base and add-on codes together on the claim, based on total time, at the end of each calendar month. The base code (98980) may only be reported once per calendar month.

Do not report RTM services if the:

device/system used is not FDA-approved;
time is related to any other services, such as a speech-language evaluation or treatment session; or
RTM treatment management services total less than 20 minutes in a calendar month.

Virtual Check-Ins (HCPCS Codes G2251 and G2252)

(updated 11/11/2021)

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.

G2251: Brief communication technology-based service, e.g. virtual check-in, by a qualified health care professional who cannot report evaluation and management services, provided to an established patient, not originating from a related service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of clinical discussion
G2252: Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion (not billable to Medicare)

To correctly use G2251, you should:

Ensure the service was patient-initiated.
Participate in real-time discussion with the patient. Unlike G2250, services reported with G2251 should be synchronous. There are various ways this can be done, including through a phone, other audiovisual technology, secure text messaging, or a patient portal.
Store the exchange, if available, and document the medical necessity, your clinical decision-making and recommendations, and the amount of time spent participating in the virtual check-in.

Do not bill G2251 if the virtual check-in:

was not patient-initiated;
takes less than 5 minutes;
is related to another evaluation or treatment service provided within the last 7 days; or
leads to an evaluation or treatment service within the next 24 hours or at the next available appointment.

G2251 is not separately billable to Medicare or the patient under these circumstances because it is bundled into the associated services.

Telephone Assessment and Management (CPT Codes 98966-98968)

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.

CPT 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
CPT 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 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion
CPT 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 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 21-30 minutes of medical discussion

To correctly use 98966-98968, you should:

Ensure the service was patient-initiated.
Determine whether other CTBS codes may better reflect your services. The telephone assessment codes should be reported when the patient has no access to other modes of communication or if the nature of the problem requires a lengthier discussion with the patient or caregiver.
Participate in real-time, audio-only discussion with the patient and/or caregiver. This is the only set of CTBS codes that allows payment when discussion occurs with a caregiver without the patient present.
Document the medical necessity, your clinical decision-making and recommendations, and the amount of time spent participating in the telephone assessment and management service.

Do not bill 98966-98968 if the telephone discussion:

takes less than 5 minutes;
is related to another evaluation or treatment service provided within the last seven days; or
leads to an evaluation or treatment service within the next 24 hours or at the next available appointment.

98966-98968 are not separately billable to Medicare or the patient under these circumstances because it is bundled into the associated services.

Billing Tips

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.

Resources

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 reimbursement@asha.org 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.