Use of E-Visit Codes for Medicare Part B Services During Coronavirus/COVID-19

Updated March 23, 2020

In response to the spread of Corona Virus Disease 2019 (COVID-19), the Centers for Medicare & Medicaid Services (CMS) announced that “clinicians who may not independently bill for evaluation and management visits (for example, physical therapists, occupational therapists, speech-language pathologists, clinical psychologists)” can now bill for three Medicare G-codes for "e-visits," effective immediately. The e-visit codes allow some qualified nonphysician health care professionals to report and receive payment for non-face-to-face digital communications that require a clinical decision. Prior to this announcement, audiologists, SLPs, and most other nonphysician groups could not bill Medicare for these services. It is important to note that the e-visits are not considered telepractice services. Here are the key things you need to know right now.

State Medicaid programs and commercial plans may allow audiologists and SLPs to report e-visits, but aren't required to. (new 3/23/20)

The following information outlines Medicare guidance and policy. State Medicaid agencies and commercial insurance plans have the flexibility to develop their own coverage policies related to e-visit services. Check with your payers directly to ask about coverage and payment for e-visits by audiologists or SLPs. You can direct them to this page for further information about use of these codes.

ASHA confirmed that audiologists may not bill for e-visits to the Medicare program. (updated 3/23/20)

In its press release, CMS included SLPs as an example of clinicians who may now report e-visit services, but did not mention audiologists. ASHA reached out to CMS to determine whether audiologists may also 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 e-visits are outside of the audiology diagnostic benefit category. Check with other non-Medicare payers to determine whether they will cover e-visits provided by audiologists.

The e-visit codes describe specific online communications that require a clinical decision and must meet specific criteria for appropriate billing.

The Medicare G-codes for e-visits are G2061-G2063 and include very specific parameters to determine whether an e-visit can be included on a Medicare Part B (outpatient) claim for payment.

• G2061: Qualified non-physician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the 7 days; 5–10 minutes
• G2062: Qualified non-physician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 11–20 minutes
• G2063: Qualified non-physician qualified healthcare professional assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 21 or more minutes

To correctly report G2061-G2063, the online assessment and management services must be:

• initiated by an established/existing patient,
• conducted through a patient portal,
• medically necessary (requires clinical decision-making and is not for administrative or scheduling purposes), and
• documented and stored to reflect the clinical decision-making and amount of cumulative time spent providing e-visit services to each patient.

Clinicians may report an e-visit code only once per seven consecutive days. Select the appropriate G-code based on the cumulative time spent providing e-visit services to each patient, through a patient portal, over the course of the seven days. Day one of the seven days begins on the first date you provide an e-visit. Telephone calls do not count towards the time for e-visits.

See ASHA’s website for clinical scenarios describing examples of services that could be reported using G2061-G2063.

CMS provides additional guidance on appropriate use of these codes in its March 17, 2020, press release.

Append the modifier GN to indicate services provided by an SLP. (new 3/23/20)

CMS staff confirmed that SLPs should include the GN modifier on claims for e-visits. To append the GN modifier, place it in the "modifier" section of the claim, on the same line as the G-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. For example, if a clinician provides the e-visit service from their private practice, enter POS 11 for “office”. Do not enter POS 12 for the patient’s home.

Check directly with your local Medicare Administrative Contractor (MAC) to clarify additional billing and claims processing guidelines. (new 3/23/20)

ASHA provides the following information 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 e-visit services.

The e-visit codes do not replace other services, such as evaluation and treatment of speech, language, swallowing, or hearing disorders. (updated 3/23/20)

The e-visit codes do not represent real-time interactions and do not replace evaluation or treatment services described by existing Current Procedural Terminology (CPT ® American Medical Association) codes. These codes are limited in scope and reflect brief, patient-initiated check-ins or consultations that require clinical decision-making. Do not report these codes for services you would normally report using CPT codes, such as 92523 for a comprehensive speech and language evaluation. Additionally, CMS indicated the e-visits must be conducted via a patient portal, meaning that other forms of real-time or digital communication, such as e-mails outside of a portal, telephone calls, or text messages are not billable with these codes. CMS provided 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.

This is not an expansion of telepractice services.

CMS classifies G2061-G2063 as technology-based communication services, rather than as telepractice services. As a result, CMS has the authority to expand use of the e-visit codes to Medicare providers who are not authorized, by law, to provide telepractice services to Medicare beneficiaries. CMS has not extended telepractice services to audiologists and SLPs at this time. ASHA continues to advocate for expanded telepractice coverage across payers and will provide updates on the webpage on payment and coverage of telepractice services during COVID-19. 

 You may notify your patients regarding the availability of these services.

Although the patient must initiate the e-visits, clinicians can notify patients that these services are now available and authorized by Medicare. It is also important to note that the patient must verbally consent to the e-visit prior to initiation of services.

Medicare Part B (outpatient) pays for these services through the Medicare Physician Fee Schedule (MPFS).

The following table lists the national Medicare Part B payment rates for the e-visit G-codes. Actual rates will vary slightly depending on your locality. Although CMS waived cost-sharing requirements for telepractice services, the e-visits are still subject to Medicare’s 20% coinsurance payment from the patient because they are not part of the telepractice benefit. The MPFS does not deduct this amount, so the actual payment by Medicare is 20% less than outlined below. You must make reasonable efforts to collect the 20% coinsurance from the Medicare beneficiary.

2020 MPFS Payment Rates

Resources

Contact reimbursement@asha.org for additional information. Monitor ASHA’s website for the latest national and federal developments related to Medicare, Medicaid, and commercial insurance coverage of telepractice services during COVID-19.