July 25, 2024
By: Laura Manser, CPC, CDEO, CIRCC, CPMA, CEMC, RCC, Director of Provider Education
In our ever-evolving healthcare landscape, teleradiology continues to play a crucial role. Let’s dive into some key points about Evaluation and Management (E/M) visits performed via telemedicine, with a focus on new patient encounters.
New Patients: More Than Just a Phone Call
Telephone-Only Visits: Not billable for new patients
Required: Audio-visual communication
Why the Distinction? The Centers for Medicare & Medicaid Services (CMS) and most commercial payers mandate audio-visual communication for new patient telehealth encounters. This requirement ensures:
- A comprehensive evaluation
- Establishment of a physician-patient relationship
- Higher quality of care
Established Patients: Some Flexibility
Audio-only visits may be permissible
Always verify specific payer policies
Coding and Documentation: Key to Compliance
When documenting and coding telemedicine E/M visits:
- Use appropriate telehealth place of service codes
- Apply required modifiers indicating remote service
- Document technology used (e.g., “visit conducted via secure video conferencing”)
- Obtain and document patient consent for telehealth services
Latest Guidance
The American College of Radiology (ACR) emphasizes the importance of state-specific telehealth laws and regulations. Some states have permanent telehealth policies, while others are still operating under COVID-19 emergency orders.
Remember: Payer policies can differ from Medicare rules. Always check the most current guidelines from each payer.
Tip: The ACR recommends radiologists ensure they’re licensed in the state where the patient is physically located during the telehealth visit to comply with state medical board requirements.
By staying informed and adhering to these guidelines, radiology practices can effectively navigate the telehealth landscape, ensuring proper reimbursement and maintaining compliance.
Resources:
- Centers for Medicare & Medicaid Services (CMS) “Medicare Telemedicine Health Care Provider Fact Sheet” https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet
- American College of Radiology (ACR) “ACR Radiology Coding Source™” https://www.acr.org/Practice-Management-Quality-Informatics/Coding-Source
- American Medical Association (AMA) “AMA Telehealth quick guide” https://www.ama-assn.org/practice-management/digital/ama-telehealth-quick-guide
- Medicare Learning Network (MLN) “Telehealth Services” Booklet https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/TelehealthSrvcsfctsht.pdf
- Health and Human Services (HHS) “Telehealth: Delivering Care Safely During COVID-19” https://www.hhs.gov/coronavirus/telehealth/index.html
Note to Our Readers: Please note that while these are authoritative sources, healthcare regulations and guidelines can change rapidly. We encourage our readers to verify the most up-to-date information, especially regarding state-specific regulations and individual payer guidelines.
Laura Manser CPC, CDEO, CIRCC, CPMA, CEMC, RCC, is the Director of Provider Education at PBS Radiology Business Experts. With 24 years of radiology experience, she is a trusted subject matter expert in coding, auditing, and documentation improvement. A dedicated educator, Laura trains coders and physicians to enhance coding accuracy, documentation quality, compliance, and revenue optimization through tailored programs. Holding multiple certifications from AAPC and RCCB, Laura is known for her proactive leadership, strong work ethic, and commitment to excellence in radiology.