Into the Weeds of Virtual Visit Coding

So there I was last week… Smiling to myself. Patting myself on the back. Thinking all the while, “I’ve got this virtual medicine coding thing down.”

Yeah. Riiiiiiight.

Medical coding is challenging enough. First, you have to figure out how complicated the patient encounter is. This is based on how many checkboxes you can click off on a multi-system list that requires years of training to fill out correctly. Then, you have to be mindful of the amount of time it has taken you to perform these activities. You must then translate all of this mumbo jumbo into an amorphous series of numbers that correspond to an arcane description in a document that resembles a 1978 telephone book.

Did I mention that you also have to tag ICD-10 codes to all of this? Don’t even get me started on that one…

And now you’re telling me that, in addition to all of this rigamarole, I have to figure out how to convert this all to over to a virtual visit? With props to Leslie Nielsen, surely you can’t be serious… Unfortunately, CMS and your payors are completely serious. And don’t call them Shirley.

My healthcare system sent out this great tip sheet that told me exactly which button to click for each type of video visit. Easy, right? That’s what had me smiling. “This is going to be a piece of cake!” I whispered to myself. But then that little twinge of doubt started to itch at the back of my skull as I thought about this a little more on my drive home from the hospital. What exactly is that little button doing when I click on my visit type in my EHR? I know that it’s triggering a code, but which code? Are modifiers dropping along with that code? What if something happens and that little button goes missing one day as EHR customizations are wont to do from time to time?

Like any good doc when she doesn’t know exactly what to do with a symptom or a diagnosis, I turned to my local internet search engine. The more I looked, the more contradictions I found. And with this COVID-19 business? All bets are off. Teleheath coding is a slippery as a greased-down eel. Things are updating daily. The more I dug in, the more I slid into the weeds.

I started peppering my local coding goddess with all kinds of questions, bless her patient heart. As she started to fish around more, we both started to figure things out. I am definitely not a coding expert, but I would like to sum up a few things that I feel I learned this past week for what they are worth:

Video telehealth coding

  1. Video telehealth encounters require an audio and a visual component in real-time. Recordings don’t count. Telephone-only conversations don’t count… They have their own rules and codes.
  2. Your coder should be your best friend! Make sure he/she knows how each of your payors like to work with this. There have been many updates, especially since 2017. Depending on which payor you’re dealing with and which state you’re in, you may be working with a much older version of the current coding convention.
  3. Generally, you will still use your standard E&M codes for New and Established patients, BUT!! You must add some information. The Place of Service code for video visits [POS 2 according to CMS guidelines] needs to be included in the right spot when you submit your billing. Additionally, there are two modifiers: GT [which is older and essentially overridden in 2017, but still used by some payors] and 95 [newer code not recognized by every payor]. At least one of these modifiers may also need to be submitted based on which payor you are billing.

telephone encounter coding

Telephone visits are a different beast entirely. They have some very special rules:

  1. These are audio-only encounters between a patient and a provider.
  2. These are for Established patients only!
  3. These should be initiated by the patient and generally unscheduled. [Note: You should verify this is the case with the rapid COVID changes going on before taking my word on it! These sorts of restrictions are getting slippery in this environment.]
  4. These encounters may not be used to address a patient problem that has already been addressed within the previous seven days.
  5. Telephone visits use different codes than the video visits. Look for the 9944x family in your favorite CPT source to determine which time range matches your encounter best.

The not-so-quick-and-dirty summary…

I would love to give you a quick, easy-to-follow guideline that will solve all of your problems, but unfortunately, this system is just a little too complex for that. My best advice is to check with your coder and to get feedback on what you’ve billed already to see if it was accepted or denied. Again, each payor can be a little different. Don’t take anything for granted here.

clickable goodness

Instead of the usual Downloadable Goodness, I would like to provide you with some useful links to CMS documentation that I found to be helpful as I waded through the tall grass on this one:

CMS Telehealth Services [overview]

CMS General Telemedicine Toolkit [includes COVID updates]

CMS Medicare Telemedicine Healthcare Provider Fact Sheet

CMS Place of Service [POS] Code Set

CMS Elimination of the GT Modifier for Telehealth Services [2017]

Keep the faith, my friends. Eventually, we will all reach a new normal here… And I’m betting that telehealth will play a much larger role than what we have previously seen. And then all of these coding rules will change again. Of that, I am certain.

But until then…


Photo credit: Couleur / Pixabay

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