Not All Remote Services are Telehealth: Know Your Codes!

A year and half into the coronavirus pandemic, confusion still remains over a variety of remote services that are often lumped into the same category as telehealth but have their own unique codes and billing guidelines. CMS has given them the somewhat unwieldy label of "communications technology based services" (CTBS) and this article will provide you with the details you need to know for compliance purposes.

CTBS vs. telehealth services: Knowing the differences

Now let's review the CTBS codes and their requirements.

Virtual check-ins (G2010, G2012)
Remote evaluation of recorded video/images (G2010)

  1. This service pays the provider to examine a patient-submitted image or video of a medical condition or complaint, and then contact the patient to give them their interpretation of the data.
  2. The response back to the patient must occur within 24 hours of the provider's review.
  3. This service is usually limited to established patients, but this requirement is waived by Medicare for the duration of the COVID-19 Public Health Emergency (PHE).
  4. This service cannot be related to an E/M visit performed within the previous 7 days, nor result in an E/M visit or service within 24 hours of the date of service (or next available appointment). The idea here is that CMS considers G2010 bundled into a previous E/M (or future E/M) if they address a "related" problem. It will be important to ensure distinct diagnosis codes are captured to differentiate this from any unrelated E/Ms done within the time windows specified.

Brief communication technology-based service, e.g. virtual check-in by physician/QHP (G2012)

  1. This is a quick "virtual check-in" done by a physician (not a non-physician practitioner). The usual requirement for the patient to be established is waived during the PHE declaration.
  2. Documentation must show at least 5 minutes of time spent in technology-based communication (audio-only is acceptable) is spent with the patient. This is an explicit requirement for amount of time to be quantified in the documentation.
  3. This service cannot be related to an E/M visit performed within the previous 7 days, nor result in an E/M visit or service within 24 hours of the date of service (or next available appointment). The idea here is that CMS considers G2012 bundled into a previous E/M (or future E/M) if they address a "related" problem. It will be important to ensure distinct diagnosis codes are captured to differentiate this from any unrelated E/Ms done within the time windows specified.

Online digital Evaluation and Management Services
Online digital E/M, physician (99421, 99422, 99423)
Online digital E/M, NPP (98970, 98971, 98972)

Time requirements are as follows:


  1. This is a service that the patient must initiate using an online secure (HIPAA-compliant) platform, typically a portal of some kind or over secure email.
  2. The usual requirement for the patient to be established is waived during the PHE declaration.
  3. Over a 7-day period beginning when the physician initiates a personal review of the patient's inquiry, a specific amount of cumulative time (at least 5 minutes) must be spent in review, assessment, and management of the patient's healthcare inquiry.
  4. The communication with the patient can be done over a secure online platform, email, or phone.
  5. The code range (9942X vs. 9897X) is based on the type of provider furnishing the service.
  6. The code level is based on the amount of cumulative time documented. The time is cumulative and does not need to be consecutive within the 7-day period.
  7. This service cannot be related to an E/M visit performed within the previous 7 days nor can it occur during the postoperative period of a previously completed procedure.

Telephone E/Ms (99441-99443, 98966-98968)
Telephone assessment and management service by physician or QHP (99441, 99442, 99443)
Telephone assessment and management service by NPP (98966, 98967, 98968)

Time requirements are as follows


  1. The usual requirement for the patient to be established is waived during the PHE declaration.
  2. This service requires only audio (telephone) and has no video
  3. This is a time-based service requiring at least 5 minutes of time documented.
  4. The code range (9944X vs. 9896X) is based on the type of provider furnishing the service.
  5. The code level is based on the total amount of time spent with the patient over the phone. Time must be documented in the medical record.
  6. This service cannot be related to an E/M visit performed within the previous 7 days, nor result in an E/M visit or service within 24 hours of the date of service (or next available appointment).

Conclusion
To keep all of these various codes and their differing requirements straight, it's a good idea to print out a cheat sheet for quick and easy reference. This knowledge, together with a good workflow to ensure patient consents are being captured and recorded, will ensure reimbursement for this unique category of remote services during the ongoing pandemic while keeping everything in compliance when the inevitable audits come.

Grant Huang
Director of Content
Grant Huang brings extensive knowledge to his role as Director of Content at DoctorsManagement. He produces educational products that help ensure that auditors, coders, practice managers and administrators optimize their organization's revenue cycle while improving their compliance in today's complex regulatory environment.  Grant is an auditor with proficiency in multiple specialties, including but not limited, to orthopedics, cardiology, neurology, general surgery, obstetrics and gynecology, internal medicine and physical and occupational therapy.

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