Furnishing telehealth services is a no-brainer (pardon the pun) for mental healthcare providers. With the convenience, efficiency and popularity of telehealth, it is an easy decision for most mental health specialists to adopt this form of patient care delivery. The coronavirus pandemic has only accelerated the adoption of mental telehealth, and this trend is more than likely to last well into the future.
Unfortunately, billing for these services can be a bit more complex than the decision to implement them. The federal government has responded to the COVID-19 pandemic with relaxed requirements for telehealth services and billing, leading to the nationwide expansion of this type of care. These changed guidelines also include revisions to coding and billing for telehealth.
While this presents a great opportunity for the mental health industry, it also means providers need to update their knowledge of telehealth billing and coding for the modern era. In short, behavioral health practitioners need to familiarize themselves with the basics of telehealth billing.
COVID Brings Changes to the Mental Telehealth Billing Landscape
After the Centers for Medicare & Medicaid Services (CMS) declared the COVID-19 epidemic a public health emergency in January 2020, it also made regulatory changes to allow for more remote care. Foremost among these changes were revisions to requirements for telehealth services, including coding and billing.
Pre-COVID Telehealth Guidelines
Prior to March 2020, Medicare guidelines had fairly strict requirements for telehealth services, which were generally followed by commercial payers as well. These requirements included the following: (1) the patient had to reside in a designated rural or underserved area, (2) the patient had to go to a healthcare facility or other “originating site” (such as a physician’s office, hospital or health clinic) for services, (3) only established patients could receive telehealth services, and (4) the provider had to use a HIPAA-compliant telehealth platform.
Telehealth Guidelines in the COVID Era
When CMS instituted its telehealth expansion in response to the COVID public health emergency, these guidelines were relaxed significantly. These relaxed rules have remained in effect well into 2021 and include the following: (1) the patient can reside anywhere in the country, (2) the patient can be located at any site to receive telehealth services, including their home, (3) either new or established patients are eligible, and (4) the provider’s platform does NOT need to be HIPAA-compliant.
Behavioral Health Services Can Now Be Provided Via Telehealth
In addition, CMS expanded the behavioral health services that could be provided via telehealth during the pandemic. These expanded telehealth services and their corresponding CPT codes range widely, from psychiatric diagnostic evaluations (CPT 90791-90792) to psychotherapy (CPT 90832-90838) to psychoanalysis (CPT 90845). Most commercial payers have followed suit by adding behavioral health services to their lists of services that can be provided via telehealth.
It should be noted that there are legacy CPT codes for telehealth therapy, but these have generally fallen out of favor. CPT 98968 is the legacy code for telehealth therapy with a non-psychiatrist, while CPT 99443 is the legacy code for telephone therapy with a psychiatrist. However, it is generally advisable to use other CPT codes from the CMS expanded list of allowed telehealth services, while being sure to use the correct Place of Service codes and code modifiers as explained below.
Choosing the Place of Service Code
Effective telehealth coding and billing require the correct usage of Place of Service (POS) codes. These two-digit codes are included on healthcare professional claims to indicate the setting in which the service was provided – hospital inpatient, ER, nursing facility, office, home, etc. Now that the requirements for telehealth services have been relaxed, the rules for POS codes accompanying telehealth claims have also changed.
Before the pandemic, Medicare’s designated POS code for telehealth visits was “02.” Now providers are instructed by CMS to use the place of service where the patient would have been seen in a face-to-face visit. For mental healthcare, this means a telehealth visit where the patient is at home can be billed with POS 11, the code usually reserved for office visits.
While this change to POS code requirements applies to Medicare claims, commercial payers may differ in their guidelines. Many such payers may still require POS 02 for telehealth services. The best practice for therapists, psychologists and psychiatrists billing commercial payers for telehealth services? Check with commercial payers for their telehealth billing guidance.
Know Your CPT Code Modifiers for Mental Telehealth Billing
In addition to their POS codes, mental health providers furnishing telehealth services must also know their CPT code modifiers. These modifiers are two-digit codes linked to the CPT code that provide a further description of the services provided during the visit. For mental health providers, the most commonly used code modifiers for telehealth by far are “95” and “GT.”
CPT Code Modifier 95
CPT code modifier 95 is the usual telehealth modifier for Medicare claims. Its official description is a mouthful: “Synchronous Telemedicine Services Rendered via Real-Time Interactive Audio and Video Telecommunications Systems.” In less complex terms, the patient and provider need to be able to interact in real time during the telehealth visit, as they would during a face-to-face conversation.
CPT Code Modifier GT
Telehealth billing modifier GT has the same requirements as modifier 95. The sole difference is that modifier GT is a legacy modifier still used by many commercial payers, as opposed to Medicare claims. As with the POS code, mental health providers should check with the commercial payer for the required telehealth modifier.
How Valant Can Optimize Your Mental Telehealth Billing
Valant’s telehealth software is specially designed for behavioral health practices to maximize the positive impact of telehealth services. In addition to seamlessly integrating with Valant’s EHR software, Valant’s telehealth solution goes beyond the current COVID-era requirements imposed by CMS by being HIPAA-compliant video technology.
While CMS may have temporarily relaxed its HIPAA-compliance requirement, practitioners would be well-advised to look for permanent solutions. Other platforms like Zoom and Skype may have served well as a temporary solution when the pandemic first hit, but they are not likely to make the grade in the future.
Get a demo today to see whether Valant’s telehealth platform is the right fit for your behavioral health practice.
