physician fee schedule 2021

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Physician Fee Schedule 2021January 25, 2021

Presented by

Jean Acevedo, LHRM, CPC, CHC, CENTC, AAPC Fellow

Leading Person-Centered Care1

About the SpeakerJean Acevedo, LHRM, CPC, CHC, CENTC, AAPC Fellow

President & Senior Consultant

Jean Acevedo, LHRM, CPC, CHC, CENTC has over 30 years of health care experience and founded Acevedo Consulting in 2000. She has a particular expertise in chart audits, compliance & education relative to physician documentation and coding. Jean has also been an expert witness in civil litigation and an investigative consultant for the DOJ and FBI in Federal fraud cases.

Recognizing physician reimbursement is moving from a pure “fee for service” model to one reimbursing for quality and value, her firm is helping ACOs and physician organizations understand the rules and nuances of diagnosis coding and the impact on Medicare RiskAdjustment (MRA) coding. She continues to provide chart reviews, physician education and compliance support to the firm’s clients.

Jean is an instructor at Florida Atlantic University where she teaches the regulatory compliance modules of FAU’s Certificate in Medical Business Management program, and a member of several Coding Institute Editorial Advisory Boards. Jean has been a Participant in CMS’ Medicare Provider Feedback Group, CMS Division of Provider Information Planning and Development since 2007 and is a member of the Jurisdiction 9 MAC’s Provider Outreach and Education Advisory Group. She presented 3 sessions on the 2021 E/M Documentation andCoding changes at the American College of Rheumatology’s annual conference in November 2020.

She is a frequently sought after speaker as she possesses the unique perspective of avoiding risk and liability while optimizingreimbursement in the highly regulated health care industry


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About Acevedo Consulting IncorporatedAcevedo Consulting Incorporated prides itself on not providing cookie-cutter programs, but a quality work product formulated and designed to meet your desired goals. We treat each client as unique, and we tailor our reviews, recommendations, training and action plans accordingly. One size does not fit all!

You can rely on us to guide you and your staff through the labyrinth of coding, reimbursement and regulatory compliance issues of the ever-changing and complex health care industry.

We are a client-focused, service-oriented firm specializing in:


• Chart Audits• Compliance & HIPAA Programs• Medicare/Medicaid credentialing• Appeal Assistance

• Education• Due Diligence• Expert Witness


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Visit: www.hospicefundamentals.com for further informationHospice Fundamentals LLC 2605 W. Atlantic Avenue, D‐102 Delray Beach, Florida 33445 561.454.8121

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Disclaimer

• The final 2021 Medicare physician fee schedule rule (CMS 1734-F) was published on 12/1/20. The COVID relief act put the add-on code, G2211, on hold. We have made every reasonable attempt to represent the new policies for E/M Office/Other Outpatient Visits in this presentation.

• Definitions and examples of 2021 E/M CPT codes do not include the entirety of the codes’ definitions or guidelines. Code selection should be made based on the complete E/M definitions and guidelines, and the supporting clinical documentation.

• This presentation reviews the changes to Office/Other Outpatient E&M codes only. The requirements for other E/M codes can be found in the CPT book and CMS’s 1995 and 1997 Documentation Requirements.


Agenda

• 2021:• Coding Office Visits based on Time• Coding Office Visits based on MDM

• Telehealth and the PHE

• Scope of Practice

• Supervision for ‘Incident to’ services

• CMS Physician Fee Schedule Lookup


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“Patients Over Paperwork”

• The Patients Over Paperwork initiative is focused on reducing administrative burden while improving care coordination, health outcomes and patients’ ability to make decisions about their own care.

• Physicians were telling CMS they continue to struggle with excessive regulatory requirements and unnecessary paperwork that steal time from patient care.

• The Administration “listened and is taking action.”

• The changes addressed those problems by proposing to “streamline documentation requirements to focus on patient care and proposing to modernize payment policies so seniors and others covered by Medicare can take advantage of the latest technologies to get the quality care they need.”


*Why Change?

• Stakeholders have said the 1995 and 1997 Documentation Guidelines for E/M visits are clinically outdated, particularly history and exam, and may not reflect the most clinically meaningful or appropriate differences in patient complexity and care.

• Furthermore, the guidelines may not be reflective of changes in technology, or in particular, the way that electronic medical records have changed documentation and the patient's medical record.

• For 2021, why start with Office visit codes?• Approximately 20 percent of allowed charges for PFS services are

for the E/M visit codes 99201-99215.


*CMS Listening Sessions, March 18, 2018 and August 22, 2019

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Evaluation and Management: Office/Other Outpatient E/M Codes

CMS, in general, accepted and incorporated the AMA changes and recommendations for E/M OVs in 2021:

• E/M documentation will be focused on MDM or Time.• Only “clinically appropriate” history and/or exam will be expected• Adopt the AMA’s new time ranges• Applies only to 99202-99215 • Office/outpatient E/M visits comprise approximately 20% of allowed

charges for PFS services.• Effective January 1, 2021


Final MPFS Rule (CMS 1734-F)

“The clinically outdated system for number of body systems/areas reviewed and examined under history and exam will no longer apply, and the history and exam components will only be performed when, and to the extent, reasonable and necessary, and clinically appropriate.”


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Biggest E/M CPT® Changes in 2021

• Only office or other outpatient visits are impacted• 99202- 99205

• Not a typo – 99201 is deleted• 99212-99215

• 99211 remains and is not impacted by these changes• No other E/M services are included in these code changes

• 3 Key Components will continue to determine code selection• Or, Time if >50% of that time is in c/cc

• Level of service will be chosen based on time or medical decision making• How time is computed changes dramatically from other codes• Determining medical decision making is more definitive• Medically appropriate history and/or physical exam• No more counting bullets!


2021: What is and isn’t changing

• Outpatient visit codes used in the office or clinic, in the Emergency Department and for patients seen in Observation Care are the only E/M codes impacted.• 99202-99205 and 99212-99215 are included in the 2021 documentation

and coding revised guidelines.• Just these 8 codes

• E/M codes for Consultations, hospital visits, SNF/NF visits, Home Care visits, and ALF visits continue to be coded based on either the 1995 or 1997 Evaluation & Management Documentation Guidelines


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2021: What is and isn’t changing

• All medical necessity requirements remain in place whether choosing 99202-99215 based on time or medical decision making. • The documented Chief Complaint/Reason for Today’s Visit and the

narrative History of Present Illness (HPI) sets the stage for determining the complexity of MDM.

• Only a “clinically appropriately History and Exam” is expected

• Previously nebulous terms such as “stable chronic illness,” or when a “problem” could be counted in determining MDM are now defined.


Practice Protocols

• A comprehensive history may still be appropriate, especially new patients• Patient history form reviewed, initial/dated, scanned into EMR

• Those elements would count per 1995 EM DG for 9924x• Online fillable forms

• PDF• Patient portal

• Need to include in your progress note? Note provided to PCP?• Know that primary care physicians are hoping to no longer receive 6+ page notes

from specialists!

• Clinically appropriate history in 2021 for OVs• But, don’t forget…

• MIPS and other QPPs


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Practice Protocols – Practically Speaking

• No need to rush and change your H&P templates

• Chief complaint/reason for the visit still required

• Easy to say “no need to change anything in the history/exam as the payers will only be looking at MDM or time,” but• Cloning and Copy & Pasting would remain a risk area at established patient visits• To support the complexity of MDM, a good narrative will be critical for proper coding

• Old fashioned, dictated SOAP charting?• Utilize speech recognition software?



Let’s look at coding 99202‐99215 based only on Time…

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Biggest Changes in 2021: Time

• Time may be used to select a code level in office or other outpatient services whether or not counseling and/or coordination of care dominates the service.• May not use time for 99211

• But Remember: For all other E/M codes, time may only be used for selecting the level of services when counseling and/or coordination of care dominates the service. • Consultations, Home/ALF visits, Hospital/SNF visits


Time: Countable Activities

Physician/other qualified health care professional time includes the following activities,when performed on the date of the OV: [emphasis added]• preparing to see the patient (e.g., review of tests) • obtaining and/or reviewing separately obtained history • performing a medically appropriate examination and/or evaluation • counseling and educating the patient/family/caregiver • ordering medications, tests, or procedures • referring and communicating with other health care professionals (when not separately reported) • documenting clinical information in the electronic or other health record

But only on the date of the visit• independently interpreting results (not separately reported) and

communicating results to the patient/family/caregiver • care coordination (not separately reported)


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Time*: Then vs. 2021


E/M Code Typical Time Now 2021 Time

99202 20 15‐29

99203 30 30‐44

99204 45 45‐59

99205 60 60‐74

99211 5 N/A (no time listed)

99212 10 10‐19

99213 15 20‐29

99214 25 30‐39

99215 40 40‐54

*AMA and CMS data files

Qualifying Time

• The office/other outpatient E/M services for which these guidelines apply require a face-to-face encounter with the physician or other qualified health care professional.

• For office or other outpatient services, if the physician’s or other qualified health care professional’s* time is spent in the supervision of clinical staff who perform the face-to-face services of the encounter, report 99211

*Qualified Health Care Professional: a clinical provider who is allowed to report an E/M code; typically includes MD, DO, DPM, ARNP, PA, CNS, CRNA, CNM


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New Concept: Time and Shared/Split Visits

• A shared or split visit is defined as a visit in which a physician and other qualified healthcare professional(s) jointly provide the face-to-face and non-face-to-face work related to the visit.

• When time is being used to select the appropriate level of a service for which time-based reporting of shared or split visits is allowed, the time personally spent by the physician and or other qualified health care professional(s) assessing and managing the patient on the date of the encounter is summed to define total time.

• Only distinct time should be summed for shared or split visits (i.e., when two or more individuals jointly meet with or discuss the patient, only the time of one individual should be counted).


New Concept: Time and Shared/Split Visits

• We will have to see how Medicare looks at this new definition of a shared/split visit• Not mentioned in CMS 1734-F

• CMS’ definition of a shared/split visit (at this time) only applies to hospital inpatient and hospital outpatient visits• And, is not based on time


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Documenting Time Spent

• It is reasonable to require documentation of the actual activities and the amount of time spent in each.

• We do not recommend use of an all-encompassing macro that memorializes activities that may be counted towards time whether all of them were actually performed.

• Consider which of the following examples might be more easily accepted by Medicare or any other third party payer.


Impact Example


Prior to 2021

Stable patient with anxiety and COPD seen to discuss meds and recent PFTs. Has questions and concerns about the progression of his COPD and Rx.

Visit lasts 45 minutes, with 30’ F2F and 15’ pre-visit time reviewing test results, last OV

MDM = 99213 (2/2/Mod = Low)

Time = 99214 (25 minutes)Pre-visit time cannot be counted

2021

• Stable patient with anxiety and COPD seen to discuss meds and recent PFTs. Has questions and concerns about the progression of his COPD and Rx.

• Visit lasts 45 minutes, with 30’ F2F and 15’ pre-visit time reviewing test results, last OV

• MDM = 99214 (Mod/Limited/Mod = Moderate)

• Time = 99215 (40-54 minutes)

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EMRs and Time

• How will the pre- and post visit time be documented/captured?

• How will the time of the NPP and the physician each be documented and captured in a shared visit?

• Possible upside of this new definition of time: notes completed same day?


AAFP FAQs on Time

How should total time be documented?

The physician or QHP’s documentation needs to justify the time spent for the visit. Use your documentation to justify the medical necessity for the

level of service that is being billed. Do not document a time range (even though the CPT® code description identifies a time range for each E/M code).

Document the actual time spent precisely.


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AAFP FAQs on Time

If I am leveling the visit based on total time, do I still need to document an assessment and plan (A/P)?

Yes, an A/P should always be documented for each visit. The A/P may provide additional information that will allow your visit to be leveled if the time

statement does not have enough information. if the A/P is not documented and the total time is ambiguous or missing, the visit may be unbillable. If you

document both MDM and total time, you can level the visit based on whichever is more advantageous, but you still must present documentation. Documentation of an A/P is also important in establishing medical necessity

and maintaining continuity of care.


AAFP FAQs on Time

If I am leveling the visit based on total time and have also provided additional time-based services (e.g., advance care planning, tobacco

cessation counseling, etc.) how do I document time for those services?

Make sure to document time separately for each of those services in order to bill for them separately. The time for each service must be carved out

of the total time. Example (for billing 99213-25 and 99406): A total of 25 minutes was spent on this visit, with 20 minutes spent reviewing previous

notes, counseling the patient on DM and HTN, ordering tests, refilling meds, and documenting the findings in the note. An additional 5 minutes was spent

on tobacco cessation counseling, discussing the importance of quitting, options for medications and a quit plan.


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AAFP FAQs on Time

If I am leveling the visit based on total time and have also provided additional time-based services (e.g., advance care planning, tobacco

cessation counseling, etc.) how do I document time for those services?

Make sure to document time separately for each of those services in order to bill for them separately. The time for each service must be carved out

of the total time. Example (for billing 99213-25 and 99406): A total of 25 minutes was spent on this visit, with 20 minutes spent reviewing previous

notes, counseling the patient on DM and HTN, ordering tests, refilling meds, and documenting the findings in the note. An additional 5 minutes was spent

on tobacco cessation counseling, discussing the importance of quitting, options for medications and a quit plan.


Key Takaways


As of 1/1/2021, physicians/NPPs will be able to choose time to select a code level for E/M office/other outpatient codes 99202‐99205/99212‐99215, whether or not

counseling or coordination of care dominates the service.

For other E/M subcategories, CPT® rules remain intact. That is, time may be used for selecting the level of E/M services (e.g., Consultations) only when counseling or

coordination of care dominates the encounter.

In computing total time, do NOT include time spent in any activity spent by other clinical staff

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2021 OV Coding Guidelines for Medical Decision Making

New Patients


99202 Office or other outpatient visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and straightforward medical decision making. When using time for code selection, 15‐29 minutes of total time is spent on the date of the encounter.

99203 …low level of medical decision making. When using time for code selection, 30‐44 minutes of total time is spent on the date of the encounter.

99204 …moderate level of medical decision making. When using time for code selection, 45‐59 minutes of total time is spent on the date of the encounter.

99205 …high level of medical decision making. When using time for code selection, 60‐74 minutes of total time is spent on the date of the encounter.

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Established Patients


99211 Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician or other qualified health care professional. Usually, the presenting problem(s) are minimal.

99212 …which requires a medically appropriate history and/or examination and straightforward medical decision making. When using time for code selection, 10‐19 minutes of total time is spent on the date of the encounter.

99213 …low level of medical decision making. When using time for code selection, 20‐29 minutes of total time is spent on the date of the encounter.

99214 …moderate level of medical decision making. When using time for code selection, 30‐39 minutes of total time is spent on the date of the encounter.

99215 …high level of medical decision making. When using time for code selection, 40‐54 minutes of total time is spent on the date of the encounter.

Complexity of Medical Decision Making


3 Variables – OVs prior/All other E/M

1. Number of diagnoses and/or management options

2. Amount &/or complexity of data reviewed

3. Table of the risk of complications, morbidity and mortality based on the patient’s presenting problem(s), diagnostics ordered, and/or management options.

3 Elements -2021 Office/Other OP Visits only

1. Number and Complexity of Problems Addressed

2. Amount and/or Complexity of Data to be Reviewed and Analyzed

3. Risk of Complications and/or Morbidity and Mortality of Patient Management

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MDM Definitions

• Problem: A problem is a disease, condition, illness, injury, symptom, sign, finding, complaint, or other matter addressed at the encounter, with or without a diagnosis being established at the time of the encounter.

• Problem addressed: A problem is addressed or managed when it is evaluated or treated at the encounter by the physician or other qualified health care professional reporting the service. This includes consideration of further testing or treatment that may not be elected by virtue of risk/benefit analysis or patient/parent/guardian/surrogate choice. Notation in the patient’s medical record that another professional is managing the problem without additional assessment or care coordination documented does not qualify as being ‘addressed’ or managed by the physician or other qualified health care professional reporting the service. Referral without evaluation (by history, exam, or diagnostic study[ies]) or consideration of treatment does not qualify as being addressed or managed by the physician or other qualified health care professional reporting the service.


MDM Definitions

• Stable, chronic illness: A problem with an expected duration of at least a year or until the death of the patient. For the purpose of defining chronicity, conditions are treated as chronic whether or not stage or severity changes (eg, uncontrolled diabetes and controlled diabetes are a single chronic condition). ‘Stable’ for the purposes of categorizing medical decision making is defined by the specific treatment goals for an individual patient. A patient that is not at their treatment goal is not stable, even if the condition has not changed and there is no short- term threat to life or function. For example, a patient with persistently poorly controlled blood pressure for whom better control is a goal is not stable, even if the pressures are not changing and the patient is asymptomatic. The risk of morbidity without treatment is significant. Examples may include well-controlled hypertension, non-insulin dependent diabetes, cataract, or benign prostatic hyperplasia. [emphasis added]


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Element #1. Number and Complexity of Problems Addressed

• Multiple new or established conditions may be addressed at the same time and may affect medical decision making.

• Symptoms may cluster around a specific diagnosis and each symptom is not necessarily a unique condition.

• Comorbidities/underlying diseases, in and of themselves, are not considered in selecting a level of E/M services unless they are addressed and their presence increases the amount and/or complexity of data to be reviewed and analyzed or the risk of complications and/or morbidity or mortality of patient management.

• The final diagnosis for a condition does not in itself determine the complexity or risk, as extensive evaluation may be required to reach the conclusion that the signs or symptoms do not represent a highly morbid condition.

• Multiple problems of a lower severity may, in the aggregate, create higher risk due to interaction.


Element #2. Amount and/or Complexity of Data to be Reviewed and Analyzed

• Test: Tests are imaging, laboratory, psychometric, or physiologic data. A clinical laboratory panel (eg, basic metabolic panel [80047]) is a single test. The differentiation between single or multiple unique tests is defined in accordance with the CPT code set.

• External: External records, communications and/or test results are from an external physician, other qualified health care professional, facility or healthcare organization.

• External physician or other qualified healthcare professional: An external physician or other qualified health care professional is an individual who is not in the same group practice or is a different specialty or subspecialty.


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Element #3: Risk of Complications and/or Morbidity and Mortality of Patient Management

• Definitions of risk are based upon the usual behavior and thought processes of a physician or other qualified health care professional in the same specialty. Trained clinicians apply common language usage meanings to terms such as ‘high’, ‘medium’, ‘low’, or ‘minimal’ risk and do not require quantification for these definitions, (though quantification may be provided when evidence-based medicine has established probabilities).

• For the purposes of medical decision making, level of risk is based upon consequences of the problem(s) addressed at the encounter when appropriately treated. Risk also includes medical decision making related to the need to initiate or forego further testing, treatment and/or hospitalization.


Element #3: Risk of Complications and/or Morbidity and Mortality of Patient Management

• Independent historian(s): An individual (eg, parent, guardian, surrogate, spouse, witness) who provides a history in addition to a history provided by the patient who is unable to provide a complete or reliable history (eg, due to developmental stage, dementia, or psychosis) or because a confirmatory history is judged to be necessary. In the case where there may be conflict or poor communication between multiple historians and more than one historian(s) is needed, the independent historian(s) requirement is met. [emphasis added]


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Medical Decision Making

• Four types of medical decision making are recognized: 1. straightforward, 2. low, 3. moderate, and 4. high.

• When the physician or other qualified health care professional is reporting a separate CPT code that includes interpretation and/or report, the interpretation and/or report should not be counted in the medical decision making when selecting a level of office or other outpatient service.



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Add‐On Codes for OVs

E/M Office Visits 2021: Add-on Codes

1. G2211: Visit complexity inherent to evaluation and management associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient’s single serious condition or a complex condition(Add-on code, list separately in addition to office/outpatient evaluation and management visit, new or established)

Postponed through 2023


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E/M Office Visit Codes 2021: Prolonged Services Codes

• 99417 (Prolonged office or other outpatient evaluation and management service(s) beyond the minimum required time of the primary procedure which has been selected using total time, requiring total time with or without direct patient contact beyond the usual service, on the date of the primary service, each 15 minutes of total time (List separately in addition to codes 99205, 99215 for office or other outpatient Evaluation and Management services) (strike outs and emphasis added 9/9/20)• Can only be used with 99205 and 99215 • Differs from CMS’s proposed time threshold • Not payable by Medicare• All prolonged time spent on the date of the primary office/outpatient E/M visit code, which is the

24-hour period for the date of service reported for the primary office/outpatient E/M visit code.

• Non-face to face prolonged services 99358/99359 and face to face prolonged services 99354/99355 no longer reportable with any office/outpatient visit

• Effective January 1, 2021


E/M Office Visit Codes 2021: Prolonged Services Codes

• G2212: (Prolonged office or other outpatient evaluation and management service(s) beyond the maximum required time of the primary procedure which has been selected using total time on the date of the primary service, each additional 15 minutes by the physician or qualified healthcare professional, with or without direct patient contact (List separately in addition to CPT® codes 99205, 99215 for office or other outpatient Evaluation and Management services) (strike outs and emphasis added 9/9/20)

• Can only be used with 99205 and 99215 • All prolonged time spent on the date of the primary office/outpatient E/M visit code, which is

the 24-hour period for the date of service reported for the primary office/outpatient E/M visit code.

• Payment to be approximately $22 per 15-minute segment

• Non-face to face prolonged services 99358/99359 and face to face prolonged services 99354/99355 no longer reportable with any office/outpatient visit

• Effective January 1, 2021


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Use of 99417 or G2212

• All time reported for code selection must be unique and medically necessary.• Do not count the 5 minutes the PA/NP and MD/DO discussed the patient as 10 minutes; only 5 unique

minutes

• Do not count the 3 minutes reviewing the cervical spine x-ray in your PAC system if you’ll be billing for the x-ray.

• Do count the 3 minutes spent explaining to your x-ray tech exactly what views you wanted for the patient’s x-rays and anything to zero in on, even if you’re billing for the x-ray.


CODE Time Range CPT® CMS

99205 60‐74 min. 99417 at 75 minutes G2212 at 89 minutes

99215 40‐54 min. 99417 at 55 minutes G2212 at 69 minutes


Other Things to Know About The2021 Medicare Part B PFS

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Payment Factors for 2021

• 2021 Conversion Factor: $34.893• Up from $32.4085 due to a 3.75% increase mandated in the COVID

relief act.

• COVID relief act signed into law over the 2020 Christmas holiday• Held off on implementing +G2211 for 3 years

• Through CY 2023• 2% sequestration reduction held off through March 2021


Payment Factors for 2021

• 2021 Conversion Factor: $34.893• Up from $32.4085 due to a 3.75% increase mandated in the COVID

relief act.

• COVID relief act signed into law over the 2020 Christmas holiday• Held off on implementing +G2211 for 3 years

• Through CY 2023• 2% sequestration reduction held off through March 2021


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2020 vs 2021 Allowables


Code 2020 2021

99203 $112.06 $118.31

99204 $173.22 $176.90

99205 $218.87 $233.76

99214 $112.49 $135.46

99215 $153.21 $189.57

G2212 n/a $35.01

https://www.cms.gov/apps/physician‐fee‐schedule/search/search‐criteria.aspx

Sample of Office Visit CodesFees are Florida Locality 3

As of 1/24/21not

updated for 2021

Public Health Emergency

• On 1/7/21, Secretary Azar extended the PHE another 90 days.

• So, telehealth flexibilities available during this time have been extended through April 20, 2021

• Telehealth Categories• Services permanently added to the list of covered telehealth services• Temporary list of services added during the PHE that will remain on the

list through the year in which the PHE ends.

https://www.phe.gov/emergency/news/healthactions/phe/Pages/covid19-07Jan2021.aspx


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Telehealth: Permanently Added as Medicare Telehealth Services

• Group psychotherapy (90853)

• Domiciliary, rest home services, established patient (99334-99335)

• Home visits, established patient (99347-99348)

• Cognitive assessment/care planning services (99483)

• Prolonged services (G2212)

• Psychological and neuropsychological testing (96121)


Telehealth: Remain Temporarily* Added as Medicare Telehealth Services

• Domiciliary, rest home services, established patient (99336-99337)

• Home visits, established patient (99349-99350)

• ED visits (99281-99285)

• SNF/NF d/c day management (99315, 99316)

• Psychological/neuropsychological testing (96130-96133, 96136-96139)

• Therapy services ((97161-97168, 97110, 97112, 97116, 97535, 97750m97755, 97761,92521-92524, 92507)

• Hospital d/c day management (99238, 99239)

• InPt neonatal & pediatric critical care, subsequent (99469, 99472, 99476)

• Continuing neonatal intensive care services (99478-99480)

• Critical care services (99291, 99292)

• ESRD monthly capitation payment (90952, 90953, 90956,90959, 90962)

• Subsequent observation/observation d/c day management ( 99217,99224-9922


*Through the end of the year in which the PHE for COVID019 ends (e.g. Category 3 services)

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Telehealth: Eliminated once the PHE ends as Medicare Telehealth Services

• Initial SNF/NF visits (99304-99306)

• Initial hospital care (99221-99223)

• Radiation treatment mgmt (77427)

• Domiciliary/rest home, new patient (99324-99328)

• Home visits, new patient (99341-99345)

• Inpatient neonatal/pediatric critical care (99468, 99471,994975, 99477)

• Initial neonatal intensive care (99477)

• Initial observation/observation d/c mgmt ( 99218-99220, 99234-99236)

• Medical nutrition therapy (G0271)


Telehealth: Other Finalized Policies

• Frequency limitation for subsequent SNF/NF telehealth visits (99307-99310) of one visit every 14 days.

• Was only one telehealth visit every 30 days.

• LCSWs, CPs, LPTs, OTRs, SLP can furnish the brief online assessment and management services as well as virtual check ins and remote evaluation services.

• G2250: Remote assessment of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment

• G2251: Brief communication technology-based service, e.g. virtual check-in, by a qualified health care professional who cannot report evaluation and management services, provided to an established patient, not originating from a related service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of clinical discussion


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Telehealth: Other Finalized Policies

• “Direct supervision” may be provided using real-time, interactive audio and video technology through the later of the end of the calendar year in which the PHE ends or December 31, 2021.

• “We have also received questions as to whether services should be reported as telehealth when the individual physician or practitioner furnishing the service is in the same location as the beneficiary; for example, if the physician or practitioner furnishing the service is in the same institutional setting but is utilizing telecommunications technology to furnish the service due to exposure risks. We are, therefore, reiterating in this final rule that telehealth rules do not apply when the beneficiary and the practitioner are in the same location even if audio/video technology assists in furnishing the service.”


Scope of Practice Changes

• Supervision of diagnostic tests is now allowed by nurse practitioners, certified nurse specialists, physician assistants, certified nurse midwives, and CRNAs

• Florida ONLY: our Patient Self Referral Act of 1992 requires a Florida licensed physician to be in the office suite at the time certain imaging studies are performed in a physician-owned practice

• Pharmacists may provide services incident to a physician with all incident to requirements met, including physician supervision.

• Pharmacists still cannot bill E/M services


1/25/2021

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ePrescribing Mandate for Part D Drugs

• The rule requiring Part B providers to eRx controlled substances still went into effect 1/1/21, but to spare doctors/NPPs the add’l cost and effort to gear up to do this during the PHE,

• Practices that prescribe controlled substances for Part D patients have an extra year to switch to ePrescribing for schedule II-V drugs.

• Compliance date 1/1/22



Acevedo Consulting Incorporated2605 West Atlantic Avenue, Suite D-102

Delray Beach, FL 33445561.278.9328

[email protected]

physician fee schedule 2021

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