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The analysis of any legal or medical billing is dependent on numerous specific facts — including the factual situations present related to the patients, the practice, the professionals and the medical services and advice. Additionally, laws and regulations and insurance and payer policies are subject to change. The information that has been accurate previously can be particularly dependent on changes in time or circumstances. The information contained in this web site is intended as general information only. It is not intended to serve as medical, health, legal or financial advice or as a substitute for professional advice of a medical coding professional, healthcare consultant, physician or medical professional, legal counsel, accountant or financial advisor. If you have a question about a specific matter, you should contact a professional advisor directly. CPT copyright American Medical Association. All rights reserved. CPT is a registered trademark of the American Medical Association.


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2019 Remote Communication Technology

Brief Communication Technology-Based Service

Brief communication technology-based service would include check-in services used to evaluate whether or not an office visit or other service is necessary. This service would be billable when a physician or other quali­fied health care professional has a brief non-face-to-face check-in with a patient via communication technology to assess whether the patient’s condition necessitates an office visit and when it does not result in an office visit.

GVCI1 - Brief communication technology based service, e.g. virtual check-in, by a physician or other quali­fied health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.

For instances when the brief communication technology-based service originates from a related E/M service provided within the previous 7 days by the same physician or other qualifi­ed health care professional, the service would be considered bundled into the previous E/M service and would not be separately billable. Likewise, if the service leads to an E/M in-person service with the same provider within 24 hours or the next available appointment it would also be bundled into the pre-visit time. However, if no visit is associated with the interaction it would be separately billable under GVCI1 and paid $14 under the proposal. CMS believes that through the check-ins practitioners would be able to mitigate the need for potentially unnecessary office visits. Only established patients would be eligible for this service. CMS does not propose any frequency limits on the code

Remote Professional Evaluation of Patient-Transmitted Information

CMS proposes creating a specific new code to describe remote professional evaluation of patient-transmitted information conducted via pre-recorded “store and forward” video or image technology. These services would not be subject to the Medicare telehealth restrictions because they could not substitute for an in-person service currently payable separately under the PFS. these services may be used to determine whether or not an office visit or other service is warranted.

GRAS1 - Remote evaluation of recorded video and/or images submitted by the patient (e.g., store and forward), including interpretation with verbal follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment.

As is the case for the virtual check-ins described previously, in instances when the brief communication technology-based service originates from a related E/M service provided within the previous 7 days by the same physician or other qualified health care professional, the service would be considered bundled into the previous E/M service and would not be separately billable. Likewise, if the service leads to an E/M in-person service with the same provider within 24 hours or the next available appointment it would also be bundled into the pre-visit time. If neither of these scenarios occurs, then the service is a stand-alone service that is separately billed. CMS plans to value the service by a direct crosswalk to CPT code 93793 which in 2018 paid $12.24. CMS notes that this would be distinct from the brief communication technology-based service described above in that this service involves the practitioner’s evaluation of a patient-generated still or video image, and the subsequent communication of the resulting response to the patient, while the brief communication technology-based service describes a service that occurs in real time and does not involve the transmission of any recorded image.

Interprofessional Internet Consultation

The addition of interprofessional internet consultation codes would cover consultations between professionals performed via communications technology such as telephone or Internet. ­is would support a team-based approach to care that is often facilitated by electronic medical record technology. ­They propose to pay separately for each code and requests that the Relative Value Scale (RVS) Update Committee (RUC) at the American Medical Association assists in establishing values for the six CPT codes.

99446-99449 - Interprofessional telephone/Internet assessment and management service provided by a consultative physician including a verbal and written report to the patient's treating/requesting physician or other qualified health care professional; 5-31 minutes of medical consultative discussion and review (depending on code).

994X0 - Interprofessional telephone/Internet/electronic health record referral service(s) provided by a treating/requesting physician or quali­fied health care professional, 30 minutes

994X6 - Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician including a written report to the patient’s treating/requesting physician or other qualified health care professional, 5 or more minutes of medical consultative time

Providers would be required to obtain verbal consent, which would include making the patient aware of any cost sharing that may be applicable, in advance of the services and document the consent in the patient medical record.

CMS introduced three new RPM codes, retitled “Chronic Care Remote Physiologic Monitoring,” which largely adopt the new codes created by the American Medical Association in 2017.  The codes (CPT 990X0, 990X1, and 994X9) are intended to better reflect how RPM services can be delivered to patients. 

  1. Less treatment time required to qualify for reimbursement. CPT 99091 requires at least 30 minutes per 30-day period, whereas CPT 994X9 requires only 20 minutes per calendar month.  The new code is much easier to track on a monthly basis, and requires 33 percent less time.
  2. Separate payment for initial set-up and patient education. CPT 99091 does not offer additional reimbursement for the time spent setting up the RPM equipment or educating the patient on its use.  The new codes offer separate reimbursement for the work associated with onboarding a new patient, setting up the RPM equipment and training the patient on same. This is a very helpful move to further incentivize providers to start using these technologies with their patients. In addition, this separate payment is different from how Medicare reimburses Durable Medical Equipment (DME) suppliers (e.g., CPAP, oxygen, etc.). CMS requires the DME supplier to set up the equipment at the patient’s home and educate the patient on how to use the equipment, but does not offer separate payment for that work.
  3. Clinical staff allowed. CPT 99091 is limited only to “physicians and qualified health care professionals” and does not expressly allow the RPM service to be delivered by clinical staff (e.g., RNs, medical assistants, etc.). This means the physician or qualified health care professional must perform the full 30 minutes per 30-day period, which is a lot of time for these highly trained professionals. For some providers, this is too resource-intensive to justify the $58.68 per month reimbursement rate.  The new code allows RPM services to be performed by clinical staff.


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