On Dec. 1, 2020, the Centers for Medicare & Medicaid Services (CMS) issued a press release about the Calendar Year 2021 Physician Fee Schedule (CY 2021 PFS) Final Rule titled “Trump Administration Finalizes Permanent Expansion of Medicare Telehealth Services and Improved Payment for Time Doctors Spend with Patients.” Because there has been misunderstanding about what this means, I’m clarifying it here.
The CY 2021 PFS Final Rule permanently adds eight billing codes to the Medicare telehealth services list. That’s it. That’s what “Finalizes Permanent Expansion of Telehealth Services” means. CMS is also amending existing language to ensure we can keep using smartphones for telehealth.
To be clear, there are other changes, clarifications and reiterations related to telehealth and other virtual services (e.g., principal care management and remote patient monitoring), but the permanent addition of these eight codes really is the extent of the action behind the announcement:
- Group psychotherapy — CPT code 90853
- Psychological and neuropsychological testing — CPT code 96121. This is an add-on code for CPT code 96116.
- Level 1 established patient domiciliary, rest home, or custodial care visit — CPT code 99334. See “Service Limits” at the end of this post for more guidance.
- Level 2 established patient domiciliary, rest home, or custodial care visit — CPT code 99335. See “Service Limits” at the end of this post for more guidance.
- Level 1 established patient home visit — CPT code 99347. See “Service Limits” at the end of this post for more guidance.
- Level 2 established patient home visit — CPT code 99348. See “Service Limits” at the end of this post for more guidance.
- Cognitive assessment and care planning services — CPT code 99483
- Prolonged services — HCPCS code G2212
Table 11 in the Final Rule contains detailed descriptions of the eight Medicare telehealth billing codes. Please contact me at tbearden@comagine.org if you’d like to see the table, or go to the Federal Register to view the entire Final Rule.
Service Limits
The Final Rule states that “the patient’s home cannot serve as an originating site” and that “because the home is not generally a permissible telehealth originating site, these services could be billed when furnished as telehealth services only for treatment of a SUD or co-occurring mental health disorder,” citing the SUPPORT Act.
In my interpretation, this means CPT codes 99334, 99335, 99347 and 99348 can only be used for treatment of a substance use disorder (SUD) or a co-occurring mental health disorder for an individual with a SUD diagnosis. If I find subregulatory guidance to the contrary, Comagine Health will share it immediately. Subscribe to our newsletter to be notified.
Update
When this post was originally published, I stated the CY 2021 PFS Final Rule permanently added nine billing codes to the Medicare telehealth services list. However, the Consolidated Appropriations Act, 2021 — passed Dec. 21, 2020 — delays the permanent addition of HCPS code G2211 until 2024.