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HCCIntelligence™ Update: COVID-19 Telehealth Billing Requirements

COVID-19 Telehealth Billing Requirements

In our recent article, Providing Telephonic and Virtual Care Requirements as part of COVID-19 Precautions, available on HCCI’s COVID-19 Information Hub, we highlighted the requirements of virtual visits. We also provided an overview of the 1135 Telehealth Waiver as part of the president’s emergency declaration during the country’s current public health emergency.

We realize this is a challenging time for Home-Based Providers, and the Home Centered Care Institute (HCCI) is committed to supporting the field by providing timely information so you can make the best decisions for your practice. In response to recent questions, we’ve outlined more information below to clarify additional questions you may have.

Q: What are the current Evaluation and Management (E/M) codes that can be billed for when the services are provided via telehealth under the 1135 Waiver?

A: Here are the appropriate E/M codes:

  • Office/Outpatient CPT code range 99201-99215
  • Transitional Care Management CPT codes 99495 and 99496
  • Advance Care Planning CPT codes 99497 and 99498
  • Annual Wellness Visits HCPCS codes G0438 and G0439
  • Administration of caregiver-focused health risk assessment instrument CPT code 96161
  • Telehealth consultations ED or initial inpatient visits HCPCS code range G0425-G0427
  • Follow-up inpatient telehealth consultations in hospitals or SNF’s HCPCS range G0406-G0408

For a complete list of CPT codes, please refer to Medicare’s list of telehealth services

HCCI is awaiting official guidance from CMS on whether Home-Based Practices that historically bill only for home or domiciliary visits should be concerned about a potential heightened audit risk if they use the office visit code set during this pandemic. We realize, however, that many Home-Based Practices are choosing to use the set office visit code, in the interim, to maintain their practice. Our recommendation is to review all the facts before making the best decision for your practice and consider contacting your local Medicare Administrator Contractor (MAC) for specific guidance.

Q: What Place of Service (POS) and modifiers are required to bill for telehealth services?

A: For services furnished via telehealth, report Place of Service (02) for telehealth.

Per the CMS FAQs & The Medicare Learning Network’s March 20th update, CMS does not generally require additional or different modifiers on Medicare claims for telehealth services furnished under these waivers, except in the following three instances:

  • GQ – Telehealth services are furnished via asynchronous (store and forward) technology as part of a federal telemedicine demonstration project in Alaska and Hawaii
  • GT – Telehealth services are furnished under CAH Method II (Via interactive audio and video telecommunication systems)
  • G0 – Telehealth services are furnished for the purposes of diagnosis and treatment of an acute stroke

As an example of when receiving guidance from your local MAC is beneficial, a practice in Indiana reached out to their MAC (i.e., WPS Government Health Administrators) and was advised to use modifiers for telehealth claims.

Q: How do I contact and confirm who my local MAC is?

A: CMS has a contractor directory and map on their website that allows you to search by state to confirm your MAC along with links to each contractor’s site where you can find their Provider Contact Center phone number. You will need to call your MAC directly to request clarification on proper billing for home visits under the 1135 waiver. They may refer you to a specific governance email, however, HCCI is aware that practices are generally receiving timely responses within a few days.

It’s also important to note the requirement for practices to use an interactive audio and video telecommunications system that permits real-time communication between the provider and the patient at home even under the telehealth waiver. This means you cannot bill for an E/M visit via telehealth for phone call audio-only. However, under the U.S. Department of Health and Human Services (HHS), the Office of Civil Rights (OCR) Notification of Enforcement Discretion relaxed HIPAA requirements so that providers may use platforms such as Apple FaceTime, Skype, Zoom, the WhatsApp, etc., as a form of two-way audio and video telecommunications., a free HIPAA-compliant telemedicine platform that allows for two-way audio and video interaction with patients and caregivers, is another option. Consider checking with your Electronic Health Record (EHR) vendor as they may have technologies available for video visits, too.

If you are providing virtual services to patients via phone call audio-only, you must refer to the Virtual Check-in Codes (requirements detailed in previous HCCI article), or use other forms of reimbursement, such as care management services (e.g., Chronic Care Management) to bill for your time.

The E-visits codes, which capture time over a 7-day period for communicating and reviewing patient information on a digital communication platform, such as a patient portal or secure email, are listed below in an HCCI chart for easy reference:

For additional information, refer to the CMS General Provider Telehealth and Telemedicine Tool-kit, or contact a member of the HCCIntelligence Hotline staff at 630-283-9222 or email [email protected].

Disclaimer: This information is current as of 3/23/2020. Coding regulations are subject to change annually, and COVID-19 guidelines are changing daily. Please note for the purposes of the Home-Based Primary Care (HBPC) population: The Home Centered Care Institute (HCCI) focuses our content on CMS guidelines relevant for traditional Medicare billing.

Online Digital E/M Services_1280

HCCIntel Legislative News Practice Management Training Training & Education

Providing Telephonic and Virtual Care Requirements as part of COVID-19 Precautions

telemedicine female physicianThe Home Centered Care Institute (HCCI) understands that many Home-Based Practices and Providers are increasing the use of virtual and telephonic care as an alternative to face-to-face care, as appropriate, due to the current COVID-19 pandemic.

Though a telehealth waiver is mentioned under recent legislation (H.R.6074 – Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020), CMS initially responded to the bill advising providers to use Communication-Technology Based Services (CTBS) and interprofessional consults.

In the CMS FAQ published on 3/5/2020, Medicare directs providers to use the current CTBS services as a means of telehealth for traditional Medicare purposes. There are, however, exceptions for Medicare Advantage (MA) patients whose MA Plan offers telemedicine as one of their supplemental benefits.

On 3/17/2020, a new Medicare Fact Sheet and FAQ’s (links below) were then published, indicating authority for the expansion of telehealth under the 1135 waiver to pay for Evaluation & Management (E/M) Office visits, Hospital visits, and other specified visits in the patient’s place of residence valid 3/6/2020.

Before billing for E/M Home Visits (CPT Code Range 99347-99350) or Domiciliary Visits, e.g., assisted living and group homes (CPT Code Range 99334-99337), however, please be advised these services are not included on the list of Medicare Telehealth Services. So, in summary, E/M Office visits (CPT Code Ranges 99201-99205 and 99211-99215) can be paid under telehealth, but E/M Home and E/M Domiciliary visits cannot at this time.

Below are the limited services included on Medicare’s list of telehealth services, which Home-Based Providers typically provide and can potentially bill for − if furnished via telehealth using Place of Service (POS) code 02 for telehealth:

  • CPT codes 99495 and 99496 for Transitional Care Management
  • CPT codes 99497 and 99498 for Advance Care Planning
  • Annual Wellness Visits CPT codes G0438 and G0439
  • CPT code 96161 − Administration of caregiver-focused health risk assessment instrument (e.g., depression inventory) for the benefit of the patient, with scoring, and documentation, per standardized instrument.

CTBS Services and E-Visits (CPT Code Range 99421-99423) can be provided and billed for now and prior to the telehealth waiver without Medicare telehealth restrictions.  We’ve detailed the requirements to bill for these services below (currently, and per the 2019 Medicare Physician Fee Schedule Final Rule, there is no frequency limitation for G2012 and G2010):

G2012: Brief Communication Technology-Based Virtual Check-in

  • Includes a minimum of a 5-10-minute medical discussion by a physician or other qualified healthcare professional (e.g., Advanced Practice Providers) with the patient/caregiver; this cannot include clinical staff time
  • Communication may be audio-only (e.g., telephone) or two-way video
  • Can only be used for established patients
  • Intended to assess the patient’s condition to determine if a face-to-face (F2F) visit is needed
  • Cannot be related to an E/M F2F visit within the previous 7 days and cannot result in an E/M visit within the next 24 hours or the next available appointment
  • Requires a patient-initiated question or call
  • Verbal patient consent is required, however, please note that, as a result of the Medicare 2020 Physician Fee Schedule Final Rule, only a once-per-year annual consent is required for CTBS services as long as the patient is made aware of possible cost-sharing
  • CMS National Payment Amount: $14.80

G2010: Remote Evaluation of Recorded Video and/or images

  • Pre-recorded image and/or video of sufficient quality provided by the patient or caregiver
  • Requires documentation of consent at least once per year (may be verbal, written, or electronic)
  • Requires interpretation and follow-up to the patient and/or caregiver within 24 business hours (follow-up may be via a patient portal communication, telephone, secure text/email or two-way video)
  • Can only be used for established patients
  • CMS National Payment Amount: $12.27

Please note: In the CMS FAQ published on 3/17/20, CMS clarifies that, while these interactions must be patient-initiated, CMS does condone providers making their patients aware of these services and billing for them, as appropriate. Please keep in mind medical necessity is always a requirement of payment, and documentation needs to support the necessity and decision-making of the care provided.

  • Supporting excerpt from CMS FAQ: “We expect that these virtual services will be initiated by the patient, however, practitioners may need to educate beneficiaries on the availability of the service prior to patient initiation.”

CMS has explicitly stated that they do not consider Remote Patient Monitoring (RPM) Services and CTBS to be part of their definition of telehealth services. Therefore, you can bill for the above and below additional services without the regulatory restrictions of Medicare telehealth requirements (e.g., originating and distant site, geographic restrictions do not apply).

  • 99451, 99452, 99446-99449 (Interprofessional Telephone/Internet/Electronic Health Record Consultation Services)
  • 99453, 99454, 99457, 99458 (Remote Physiologic Monitoring)
  • 99091 (Review and analysis of physiologic data)
  • 99421, 99422, 99423 (Online Digital E/M by a qualified provider); Please note this service is bundled with Chronic Care Management (CCM); Refer to our 2/19/20 HCCIntelligence Webinar “What You Should Know About 2020 Coding Updates!” for further details regarding online E/M services
  • G2061, G2062, G2063 (Online Digital E/M by a nonphysician healthcare professional); Please note this service is bundled with CCM

Other Key Considerations:

  • CMS will not enforce an existing provider-patient relationship to furnish telehealth services. The Department of Health & Human Services (HHS) advised: “HHS will not conduct audits to ensure an existing provider relationship during this public health emergency.”
  • Effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers who serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency. For more information:
  • HCCI encourages all Home-Based Providers and Practices to contact their local Medicare Administrator Contractor (MAC) to inquire if they will pay for E/M Home Visits furnished via telehealth under the current telehealth waiver.

For additional information on COVID-19 regulations and legislation, please visit the CMS current emergencies page or contact a member of the HCCIntelligence Hotline staff at 630-283-9222 or email [email protected]..

You can also visit the HCCI COVID-19 Information Hub for additional information and resources.

Disclaimer: This information is current as of 3/17/2020. Coding regulations are subject to change annually, and COVID-19 guidelines are changing daily. Please note for the purposes of the Home-Based Primary Care (HBPC) population; the Home Centered Care Institute focuses our content on CMS guidelines. All G codes are used for Medicare purposes, and commercial payors utilize a corresponding set of CPT codes.


HCCIntel Tip of the Month

Keep Your Practice Financially Healthy

piggy bank and stethescope

Revenue cycle management (RCM) encompasses all the administrative and clinical functions that contribute to the identification, capture and management of patient service revenue. A periodic review of RCM basics may uncover opportunities for process improvement within your organization. Points to consider:

  • Do you have in-house support, or will you outsource RCM, billing and coding functions? If outsourced, do you receive consistent reports and feedback on your practice’s billing and coding?
  • Do your providers and support staff receive ongoing education on Evaluation and Management (E/M) and billing considerations specific to house calls?
  • Are your providers responsible for selecting their own billing codes or do you have an internal coding review?
  • Do you monitor certain services (e.g., time-based) for accuracy and completeness prior to claim submission?
  • Are progress notes locked and signed within 72 hours? Who monitors open encounter lags?
  • How quickly are claims being paid and who follows up on outstanding unpaid claims/denials?

Also, be sure not to overlook the following:

  • Credentialing – Documentation of each payer enrollment process and ensuring all providers are credentialed with each payer.
  • Office of the Inspector General (OIG) Compliance – Section 6401 of the Affordable Care Act (ACA) requires providers to develop and implement a formal health care compliance program.
  • Denial management process – Examine, resolve and/or appeal claims to recover lost revenues.

Finally, remember that, whether managed in-house or outsourced, successful RCM strategies depend on the accuracy and thoroughness of front-end tasks, such as verifying active insurance coverage prior to visits and the effective denial management process mentioned above.


Event HBPC in the News Training Training & Education Uncategorized

HCCI and NNPEN Conference: Different Strategies, Shared Vision

HCCI NNPEN joint conference

How can Nurse Practitioners (NPs) and others effectively start-up and/or expand a home-based primary care (HBPC) practice? Just ask the participants who attended the February 7- 8 joint conference hosted by the Home Centered Care Institute (HCCI) and the National Nurse Practitioner Entrepreneur Network (NNPEN) in Phoenix.

With NPs being the fastest-growing segment of HBPC providers, the conference provided attendees with critical information on planning and operating a successful and sustainable HBPC practice. Participants brought varying backgrounds and HBPC experience levels to the conference, entitled, “Blueprint for Success: Building and Growing Your Home-Based Primary Care Practice.” The first day concluded with a well-attended “Open Office Hours” segment, where participants were able to ask questions about their specific situations, which invariably applied to many in the room.

The two organizations’ strategies are necessarily distinct. HCCI focuses on professional development for NPs who have a specific interest in HBPC while NNPEN, as Sandy Berkowitz, RN, JD, and Co-founder and CEO of NNPEN, explains, “focuses on supporting nurse practitioners as professionals who want to be their own boss.”

At the same time, though, HCCI and NNPEN have a similar vision. “We share the same vision and passion to create access for a primary care population of frail and elderly patients who are vastly underserved,” Berkowitz continues, “and to explore how advanced practice providers can do well by doing good.”

In sharing her own conference takeaways, Heather Hodge, Director of Education for HCCI, said, “During the conference, I was struck again by how providers are offering HBPC through a variety of business models. It’s not a one-size-fits-all. Plus, people seemed to take something from every session that they could immediately apply to their own situations. Finally, the conference gave people a place to ask their top-of-mind questions and share their successes and challenges, like managing different state laws, payer requirements, and so on. In all, the event helped many see they weren’t alone and that, if they were having an issue, someone else probably was, too.”

For NPs and others with questions about developing or sustaining an HBPC practice, HCCIntelligence™ offers webinars and a hotline at 630-283-9222 and [email protected].


HCCIntel Tip of the Month Training

Optimizing Front Office Operations

Maximize front office efficiency
House Call programs can become more efficient, drive collaboration and enhance overall effectiveness by optimizing their daily operations. These operations can include managing phone calls, paperwork, record requests, and geographic scheduling; confirming appointments and verifying insurance, conducting patient intake and processing referrals, and assisting with practice billing and coding, among other areas.
Here are several tips to help your practice be successful:
  • Develop scripting and decision-tree guides for the front office to follow when speaking with new patients
  • Use real-time eligibility within the Electronic Health Record (EHR) to verify active patients and correct insurance prior to patients being seen
  • Consider using an electronic fax platform with E-Signature capability to streamline orders and paperwork
  • Use clear and concise patient intake and referral checklists to ensure appropriate information is collected in advance and services are explained upon enrollment
  • Define territory zones for each provider and use map-based tools to plan visits and routes
  • Don’t confirm appointments until one week to a few days beforehand to allow for schedule flexibility and ensure patients/caregivers are expecting the provider
  • Explore Health Information Exchange (HIE) options in your area for prompt access to medical records
  • Determine which services may require a review to ensure documentation and coding requirements are met and provide real-time feedback to the providers
  • Taking the time upfront to optimize these operations will prevent task duplication, promote efficiency, and increase patient and team satisfaction.
HCCI in the News News Press Releases Uncategorized

Thomas Cornwell, MD, Transitions Roles at HCCI and Joins VillageMD

Founder of Home Centered Care Institute transitions from CEO to Executive Chairman and takes on new role with VillageMD

Schaumburg, IL, March 2, 2020

Thomas Cornwell, MD
Thomas Cornwell, MD

The Home Centered Care Institute (HCCI) announced today that its founder, Dr. Thomas Cornwell, will transition his role with the organization from Chief Executive Officer to Executive Chairman, effective March 9, 2020. At that time, he will also become the Senior Medical Director of Village Medical at Home, part of VillageMD.

Since founding HCCI, Dr. Cornwell has played a critical role in fulfilling the organization’s vision to spread home-based primary care (HBPC) to more patients by generating substantial awareness of HBPC and the need for expanding house call programs and the workforce.

HCCI has also played a role in the continuation of the Independence at Home Medicare Demonstration and the Centers for Medicare & Medicaid Services’ New Payment Models; educated over 500 unique learners and 260 HBPC practices; introduced a consulting practice focused on practice management and clinical care; created six HCCI Centers of Excellence for Home-Based Primary Care™; assembled a national faculty of HBPC leaders; and taught over 1,000 students and health system leaders at three medical universities in China along with partnering with Shandong University in Jinan to create an HCCI HBPC training center.

“I am incredibly proud of the team at HCCI and know it is in good hands and well-positioned for the future,” said Dr. Cornwell. “I am excited to be joining Village Medical at Home and combining their operational excellence with my twenty-five years of HBPC experience and clinical skills to further spread house calls nationally.”

Taking on his new role with Village Medical at Home means that Dr. Cornwell will no longer practice with Northwestern Medicine HomeCare Physicians. “I remain forever thankful for Northwestern Medicine’s support of HomeCare Physicians,” said Cornwell. “The numerous awards, media exposure, and national recognition we have received as a house calls practice – and, most importantly, the number of patient and caregiver lives we’ve been able to touch – are all a result of Northwestern’s incredible support.”

HCCI’s Board plans to review the existing leadership structure at their next meeting. In the interim, Julie Sacks, Chief Operating Officer, will continue to manage the daily operations of HCCI. Sacks shared her thoughts on the transition, saying, “Without Dr. Cornwell and our funders, there would be no HCCI. He had the incredible vision and passion to establish an organization that is transforming our health care system. I also consider it an honor to help steward HCCI through this important transition.”

Richard Maybury, Chairman of the Board for HCCI, also shared his perspective, adding, “Dr. Cornwell has been caring for patients in their homes for over 25 years, so his new role is a natural extension of that work. At the same time, HCCI is well-positioned for the future with a strong core of proprietary HBPC education delivered through multiple channels, a growing consulting practice, a key role in HBPC advocacy, a national network of leading academic healthcare institutions and HBPC faculty, and the right combination of experienced and tenured leaders and staff in place to take the organization forward.”

As Executive Chairman, Dr. Cornwell will be a member of the board; continue to act as a strategist; represent HCCI to the public, industry and media; and play a continued role in the organization’s ongoing growth and improvement, including fundraising.

Home Centered Care Institute

The Home Centered Care Institute (HCCI) is a national non-profit organization focused on advancing home-based primary care to ensure that medically complex and homebound or home-limited patients have access to high-quality care in their homes. HCCI works with leading academic medical centers, health systems, and industry experts to raise awareness of and advocate for expanding the model by growing the home-based primary care workforce through education and training and developing a research-based model for sustainable house call program implementation and growth. For more information, visit and follow @HCCInstitute.

Northwestern Medicine

Northwestern Medicine is the shared strategic vision of Northwestern Memorial HealthCare (NMHC) and Northwestern University Feinberg School of Medicine to transform the future of healthcare and become a premier integrated academic health system. Each day, 33,700 clinical and administrative staff, medical and science faculty, and medical students come together with a shared commitment to superior quality, academic excellence, scientific discovery and patient safety. For more information, visit


VillageMD is a leading provider of healthcare for organizations moving toward a primary care-led, high-value clinical model. The VillageMD solution provides the tools, technology, operations, and staffing support needed for physicians to drive the highest quality clinical results across a population. VillageMD works with physician groups, independent practice associations, and health systems to improve quality, deliver a first-rate patient experience, and lower costs in the communities they serve. VillageMD will continue to grow its Village Medical brand and scale its Village Medical at Home offering. VillageMD has grown to include more than 2,500 physicians across nine markets and is responsible for approximately 500,000 lives and $3 billion in total medical spend in value-based contracts. To learn more, please visit

Read the VillageMD press release here.

Read the HCCI Chairman of the Board letter here.

# # #

HCCI in the News News Press Releases

Chairman of the Board Letter

March 2, 2020
Chairman of the Board Letter

Thomas Cornwell, MD, Transitions Roles at HCCI and Joins VillageMD

On behalf of the Board of Directors, leaders and staff at the Home Centered Care Institute (HCCI), I wanted to share some exciting news with you. Dr. Thomas Cornwell, the founder and Chief Executive Officer of HCCI, will begin a new role as Senior Medical Director of Village Medical at Home, part of VillageMD, effective March 9, 2020. In this position, he will bring his experience, skills and passion from making over 33,000 house calls to VillageMD’s extensive provider network that serves over 500,000 patients in nine markets. With this change, Dr. Cornwell will no longer be HCCI’s CEO, but he will maintain a strong connection to the organization in his new role as Executive Chairman.

Dr. Cornwell has been providing home-based primary care (HBPC) for over twenty-five years, starting at a time when house calls were relatively rare. Well, they are most assuredly not as rare now – in part due to his vision, HCCI’s efforts, and as also evidenced by VillageMD’s expansion into the field. His original vision, supported by our funders, led to establishing HCCI, where he and a similarly passionate team have made great strides towards increasing access to HBPC by:

  • Generating substantial public and provider awareness of the importance of HBPC and the need for expanding the workforce.
  • Playing a role in the continuation of the Independence at Home Medicare Demonstration and the Centers for Medicare & Medicaid Services’ two New Payment Models: Primary Care First and Direct Contracting.
  • Educating over 500 unique learners and 260 HBPC practices through live workshops, pre-conferences, online courses, webinars and additional events and resources.
  • Introducing a consulting practice that supports new and existing HBPC programs through a focus on practice management and clinical care.
  • Creating six HCCI Centers of Excellence for Home-Based Primary Care™ with prominent national academic healthcare institutions and assembling a national faculty of HBPC leaders.
  • Teaching over 1,000 students and health system leaders at three medical universities in China and partnering with Shandong University in Jinan to create an HCCI HBPC training center.

I am excited about this change for two main reasons First, this new role will allow Dr. Cornwell to leverage his clinical experience and skills to an even greater extent while continuing to support HCCI and its mission to spread HBPC nationally. Second, I know HCCI has the people, infrastructure and partners in place to continue its excellent training and consulting, advocacy work, research, and focus on increasing public awareness, now and into the future.

In terms of roles, as Executive Chairman, Dr. Cornwell will be a member of the board; continue to act as a strategist; represent HCCI to the public, industry and media; and play a continued role in the organization’s ongoing growth and improvement, including fundraising. Our board will also review the existing leadership structure at our next meeting in March. In the interim, Julie Sacks, Chief Operating Officer, will continue to manage the daily operations of the organization ─ to include overseeing the senior leadership team and creating and ensuring the execution of the organization’s high-level strategies, new initiatives, and partnerships.

Due to his new role, Dr. Cornwell will no longer practice at Northwestern Medicine HomeCare Physicians. Dr. Cornwell remains forever thankful for the role Northwestern Medicine played in supporting him and HomeCare Physicians. Dr. Paul Chiang will continue to lead HomeCare Physicians and remain Senior Medical and Practice Advisor at HCCI.

The entire board wishes to thank Dr. Cornwell for his tremendous contributions and leadership as the CEO and is pleased to be able to continue to work with him in his new Executive Chairman role.  Also, we want to congratulate him on joining VillageMD, a wonderful opportunity that further spotlights the increasing visibility of HBPC.

Finally, I personally want to thank Dr. Cornwell, or “Tom” as I call him, for his friendship and for everything he’s done to make house calls a valued and visible part of the healthcare landscape.  Because, in the end, it’s all about taking care of a patient in their home ─ something I’m sure we all hope is available when we, and our loved ones, need it.

Read the VillageMD press release here.

Read the HCCI Chairman of the Board letter here.

Richard Maybury
Chairman of the Board
Home Centered Care Institute