The guidance in this article is based on years of experience navigating Medicare across state lines and understanding that clinicians rendering behavioral health services must have claims billed cleanly to get reimbursed. With all these new changes, there are expected roadblocks in the claim-approval process. We encourage you to consult with the Centers for Medicare & Medicaid Services (CMS) to ensure the accuracy of your billing practices.
According to The Centers for Medicare & Medicaid Services (CMS), the Department of Human Services (HHS) published their final rule for 2022 and have changed the Medicare physician fee schedule (PFS) along with other Medicare Part B payment policies.
Click here to see the Calendar Year (CY) 2022 Medicare Physician Fee Schedule Final Rule | CMS
After the Public Health Emergency (PHE) ends, Medicare will continue to allow behavioral health services to be rendered to Medicare patients via real-time audio/visual technology or audio-only for patients in their homes across the US. The passing of the Consolidated Appropriations Act on 12/27/2020 established this continuance.
What’s New After April 1st, 2022?
- Clinicians can document services that are rendered in-person via audio-only or audio/visual technology.
- FQ will be used to notate audio-only behavioral telehealth services ( Although it currently only applies to Medicare, private payers can make this modifier unpayable by leaving it off entirely).
o To use this modifier, clinicians must have the ability to use a video telecommunications platform (VTC). The patient does not need a video connection.
- A face-to-face visit with the clinician is required within 6 months of beginning telemedicine sessions (except for substance-use disorder treatments and patients in geographically underserved areas). This rule includes telemedicine visits before the PHE began in 2020.
o After the initial in-person visit within the first 6 months, all patients being seen via telecommunication technologies will need to have an additional in-person visit within 12 months.
- A valid exception for not attending a 12-month in-person visit must be documented in the patient’s medical record Exceptions include travel, hardship, and scheduling constraints for the patient or provider.
o The face-to-face visit can be with a different clinician of the same specialty who works in the same group.
- Place of Service (POS) 10 Telemedicine Provided in Patient’s Home
o Description: The location where health services and health-related services are provided or received through telecommunication technology. The patient is located in their home (a location other than a hospital or a facility where the patient receives care in a private residence) when receiving health services or health-related services through telecommunication technology (this code is effective January 1, 2022, and is available to Medicare on April 1, 2022).
o Like all new changes, there may be bumps in the road when conveying the location code to Medicare without rejection. POS 10 is supposed to provide clarification on the patient’s location during the service. If the patient is at home while using telecommunication technology for the service, then POS 10 is used in place of POS 2—unless instructed otherwise by CMS.
- POS 02: Telemedicine Provided Other than in a Patient’s Home
o Description: The location where health services and health-related services are provided or received through telecommunication technology. Patients are not located in their home when receiving health services or health-related services through telecommunication technology (effective January 1, 2017; the description change is effective January 1, 2022, and is applicable for Medicare on April 1, 2022).
How to Bill your Telemedicine Medicare Claim
- Place of Service (POS): This is in Box 24b on a standard CMS-1500 form.
o Choose the correct location code based on the definitions above.
- Telemedicine Modifiers Audio & Visual. The modifier will need to land in Box 24d on a standard CMS-1500 form.
o GT modifier for audio/visual services.
o FQ modifier for audio-only services.
The biggest change in 2022 is that Medicare is asking us to use POS 10 over POS 02 if the patient is receiving services virtually while they are at home. Additionally, patients who are seen via telemedicine must have a face-to-face visit within 6 months of beginning treatment.
CPT Codes Commonly Covered via Video Sessions
- 90785 Psytx Interactive Complexity
- 90791 Psych diagnostic evaluation
- 90792 Psych diag eval w/med srvcs
- 90832 Psytx pt&/family 30 minutes
- 90833 Psytx pt&/fam w/e&m 30 min
- 90834 Psytx pt&/family 45 minutes
- 90836 Psytx pt&/fam w/e&m 45 min
- 90837 Psytx pt&/family 60 minutes
- 90838 Psytx pt&/fam w/e&m 60 min
- 90839 Psytx crisis initial 60 min
- 90840 Psytx crisis ea addl 30 min
- 90845 Psychoanalysis
- 90846 Family psytx w/o patient
- 90847 Family psytx w/patient
- 90853 Group psychotherapy
- G0396 Alcohol/subs interv 15-30mn
- G0397 Alcohol/subs interv >30 min
- G0443 Brief alcohol misuse counsel
- G0444 Depression screen annual
- G2086 Off base opioid tx first m
- G2087 Off base opioid tx, sub m
- G2088 Off opioid tx month add 30
Stay up-to-date with changes in the telemental health field by taking our Telehealth Billing: 2023 Update course.
Need assistance or consultation for your insurance billing? Contact us for a consultation meeting.
By: Zaynab Hamka, Billing Consultant
Nicoletti, B. (2022, February 3). Coding telehealth visits. https://codingintel.com/coding-telehealth-visits/
Coding Intel. (2022, February 8). Payment for telephone calls during the PHE: CMS update. https://codingintel.com/payment-for-phone-calls-cms-update/
Behavioral Health Updates:
Nicoletti, B. (2022, January 31). Behavioral health and telemedicine during the PHE. https://codingintel.com/behavioral-health-and-telemedicine/
CY2022 Final Rule:
Centers for Medicare & Medicaid Services. (2021, November 3). Calendar year (CY) 2022 Medicare physician fee schedule final rule. https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2022-medicare-physician-fee-schedule-final-rule
CY2022 Telehealth Update:
Medicare Learning Network. (2022, January 14). CY2022 telehealth update medicare physician fee schedule. Centers for Medicare & Medicaid Services. https://www.cms.gov/files/document/mm12549-cy2022-telehealth-update-medicare-physician-fee-schedule.pdf