Hello. My name is Carol Yarbrough. And if you've not joined a prior session, welcome. And if you have, wow you came back. All right. This is part 2 of the Medicare list of telehealth services, telehealth definitions. 

It's going to help you navigate your way through this dizzying array of, is it on the list? Is it off the list? What does it mean? OK, next slide. Where did it come from? Why is it like this? As my friend says to me, why are you like this? 

I do have an answer about telehealth reason, not myself. It came from the Social Security Act. There's a section in there, a rule. Actually, it's a law. It's not a regulation. It's actually a law. It's not some kind of decision made by CMS. 

It's not anything that people have interpreted. This is an actual law that was put into place by Congress. And they passed a law that is embedded in the Social Security Act that ensures payment for telehealth services. This is the Genesis of everything you ever wanted to know about where this creature came from. 

It's a service via telecommunication system. I like the left in general. Because this was back in the pre Zoom days. This was like you really had to have some kind of high tech, better than, I don't know, what we would even have. 

There were no cameras embedded in our laptops back then. And what was smartphone? It was a Dick Tracy watch in a cartoon or comic strip. Anyway. A practitioner-- says physician or a practitioner. 

Let's not leave out the NPPs, please, or the PTs, or the OTs, anyone to an eligible telehealth individual, meaning someone that has Medicare coverage enrolled under this part notwithstanding, usually someone 65 or over, or with a disease that places them on permanent disability, ESRD, sickle cell. 

It means that you're just not at the same location as the beneficiary. It's across the distance. And here's a payment term. The distant site. Now, the distant site is the amount equal to the amount that such physician would have been paid had such service been furnished without the use of the telecom system. 

Telecom. Yeah, that's what we used to call it. AT&T, American Telecommunications, something, AT&T. I'm not an employee of AT&T. I don't know why I keep using that as an example. Anyway, the distance site is where the provider is, the practitioner. 

So you get paid at 100% of what you would have gotten paid. Now, the 100% means if you're in a facility, you get the professional fee portion. You don't get the facility fee portion. You get the trophy. The trophy, meaning if you're doing a 99214, you get paid for that split portion, the $150, whatever. 

And then the G0463, my favorite pick picks means it's the E&M equivalent on the facility bill that reimburses for use of the facility equipment, such as-- or equipment, that's not nice, such as an RN, anyone associated or paid for salary or otherwise by the facility, by the hospital, by the hospital outpatient department, by the FQHC. No, not that. 

You know what I'm saying. You get paid what you would have gotten paid the split fee. Now, this applies to Medicare, Medicaid. It's not apply usually to Medicare commercial insurances. Those are global payments. 

Now, global payment is what you get place of service 11, the non-facility. So if you are a provider at a non-facility and service 11, you get paid 100% of the global. So if you're at a facility, and you're a provider at a distant site, the person or the facility hosting your patient, hosting the patient at another facility outpatient department, at an FQ, in a hospital, in a box with a fox, no, kidding, no copyright infringement on Dr. Seuss. 

But they wanted people to get a little bit of money just to have the portal for the patient to look into. Say hi, doc, hundreds miles away from me. I got this pain. The payments started at $20 in 2001. 

Started at $20. Hasn't gone up that much, has it? Home was not an originating site. It was not even a gleam in CMS's eyes or Congress. So telehealth service, in general, this is interesting. It was limited to these codes. 

Professional consults. Remember those consult codes we used to get paid for? 99241 through 99275? Office visit, 992020. Not to forget 201 back then. 99201 through 99215. Office psychiatry services. 

Psychiatry. And psychology too. Limited, 90804 to 90809. And 90862. And is subsequently modified. And any additional service, specified by the secretary. So there are yearly updates. And there on an annual basis. 

And where do those come from? They come from the Medicare physician fee schedule. And they're identified in there. The additions are identified. And you can argue for or again, are you with me or against me? 

You can argue for those codes to be placed when the comment period opens up in July. Presumably, we get that the draft-- MPFS draft every year, usually in July of each calendar year. You get 90 days comment. 

You can say, you know what, I really want this code to be payable by a telehealth, by a telecom. So it is a yearly update. That's the process for the MPFS. Now, in July-- oh, look, July 1. 

When this was introduced, we had a total of 29 CPT codes. As of July 1, 2025, which is the calendar year in which this recording is made, there are a total of 282 CPT codes. Now, think about it. 

29 to start. All right. Having a global health emergency really did help expand this list. But each year, it did expand. It did. There are a permanent 115 CPT codes. Maybe I should add CPT/HCPCS. 

HCPCS encompasses CPT codes. If you hearken back to our last session, they say there are provisionally some codes on there, which means they're thinking about adding them. If you use them enough or if they're only applicable to give people a ramp down from what they were used to during the pandemic, provisionally, there's 167 on there or through the end of 2025. 

They can just take them all off. They're there provisionally. That's not a permanent CPT code on that Medicare telehealth service list. And guess what, that is how Medicare defines telehealth. It's either on the list or it's off the list. 

Oh, back to my Ken Kesey reference. You're either on the bus or you're off the-- you're off the bus? If you're not on the bus, you're not telehealth. You're not doing that telehealth service. So right now, we got 282. 

How many codes are in the AMA CPT book? At last, internet search reference point. There were over 11,000. I would not count them up. That would be crazy of me. That would be foolhardy. 

Maybe AI would count it up for me. Now, look, we got 282 codes that we use during the pandemic out of the 11,000. When you think about it, that kept a lot of people afloat health wise for the initial months. 

Percentage wise, I think it's less than 5% of all the CPT codes. Don't quote me on the math. I'm just-- anyway, it expanded a lot. It helps people keep healthy a lot. Why not have permanent coverage? Why not? 

Why not? OK. So here's the yearly update. Where is that list? Type into your favorite search engine. Medicare list of telehealth services. If you forget this URL, or that this PDF, or this presentation exists, it's updated every year. 

It also gives the originating site facility fee increase per year. It's $31 this year. 25 years after the originating site fee was originated $20. We're now up to $31. 

Oh, with the price of bread or eggs only increase by that amount. I digress. Things to note. There used to be an audio-only column. Not there anymore. What? 

You know why? I'll tell you why in a second. OK, category. So the finalized action. It means maintain it. We're maintaining it on the list. The category is that it's provisional or permanent. 

HCPCS. See? Look. CPT code, HCPCS. It's all under one column heading. What's nice about this, if you're not good at Excel, it's already filtered for you. They put the filter on there for you. 

Just click on this, filter, provisional, permanent. It'll count up the cells for you. It'll count the rows up. That's what I did. I didn't count them by hand. Anyway, look, here are all of our favorite codes. 

For behavioral health codes. Special note. Oh, the telephone codes were deleted by the AMA. You know why? Because they thought their AMA telehealth codes would be adopted by CMS. And they weren't. 

They deleted them because those AMA-specific telehealth, either audio, video, or just audio codes, were developed by the CPT committee at which representatives of CMS were in attendance. But then they had second thoughts, and they're like, well, we already got the E&M codes. 

What do we need all these extra codes for? What do we need an extra 16 codes? You don't like it. So those aren't on the list anymore. And they were deleted. 

But because there were no CPT codes created in addition to these three audio-only services, 98966 through 68, 8 psychologists can use this code. You're not an MD. You're not an NPP. 

You are a provider without medical certification even though you're educated. Yeah. Dance degree. PhD. to use these codes for telephone calls. They are time limited as well. 

OK, guess what. In 2021, Congress amended the Social Security Act to permanently waive the restrictions on provision of audio-only for telebehavioral. They put in this in-person visit within six months of initiating the service. So you got to see somebody in person, or you shouldn't get paid for that audio only or audio video only. 

It's not going to take effect until the geographic and originating site waivers terminate. We are currently in-- the time of this recording is April 2025. The geographic and originating site waivers were in a time period where these are in effect through the end of September. So the in-person requirements have been waived waves for the time being. 

There is required documentation now. If you use audio only. And this is, yes, embedded into regulatory guidance. The law. You must, in each instance You don't get to do this annually. 

You have to document that the person is at home. If you're going to say, I did this audio only to a patient's home, place of service, 10. Patient was physically present in their home. That just means they're not in a facility. 

They're not admitted. They're not in an HOPD. You're not gaming the system by getting that global payment. They're physically present in their home, temporarily in their car, in a parking lot, temporarily in a hotel room, temporarily where they're hanging their hat is their home if they have a permanent residence, right. 

Providers technically capable of using audio, video. And maybe the beneficiary can't use video. Maybe their broadband isn't robust. Maybe everyone in the neighborhood is watching Netflix, and everything keeps crashing. 

You can only use audio. Or maybe they're not having a great day. And they don't want to be on camera that day. This is behavioral health. Like some days, we just don't want to be there. 

So you have to put that into the note. You can make a smart phrase or an attestation statement. Copy paste that statement. But make sure that you say the patient didn't want to be on camera today. 

The broadband wasn't working. It's their choice. But you also have to say, you have the capability as a provider, as a clinic, as a HOPE that you do have the technology, we have the whatever to make you stronger and faster than before. OK, little shout out to the Million Dollar Man. 

So you need to document in the medical record, each time you use a modifier 93 to do a telephone call, because guess what, you get paid just as much as if you saw the patient face to face or in the clinic. You're not getting paid any less because it's audio only. 

You're still expending time. If you're using prolonged time or just the time of the initial CPT code, some of them are time base as a behavioral health provider. Please say you know this. Yeah, our services are time based. 

Or if you're a psychiatrist and you're using an E&M code, those are also time based or based on medical decision making. You get paid just as much as if the patient had come into your clinic. They want to know why you're only using it. You're only on the phone. 

Simple, right? Just remember to do it. Here's a suggested attestation that I made up. I did. I didn't copy it from anybody. Blah, blah, blah. This encounter was conducted via audio only due to patient choice. 

Or due to patient's broadband, due to patient's technology limitation. I assess the patient's current mental health status, reviewed symptoms, provided appropriate therapeutic interventions. You don't really have to put that in there But It could. 

Everything that a standard in-person event was addressed, including whatever critical element of the CPT code service you're providing. It's got to go in the note, everything. If it's not in the note, it's not part of the deal. 

We all know contracts. Like, I hired a plumber, and I asked them to install an InSinkErator. Well, if I didn't sign off that, they also fixed my faucet, I'm not going to pay for it. They didn't. I didn't want him to do that. 

I only wanted to install it, it's not in the contract. It's not part of the deal. They didn't-- if you don't document it, if your provider didn't document it, why should anyone pay you for it?