Article posted November 5, 2019
One of the more significant changes to the Medicare Physician Fee Schedule for 2019 is that CMS will now pay separately for telephone encounters with established Medicare patients that do not lead to a face-to-face office visit. This change goes into effect on January 1, 2019. Practices can charge for this service through HCPCS code G2012. Reimbursement will be approximately $10 per encounter (the Work RVU is 0.25).
HCPCS Code G2012 Description: “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.”
In order to bill for HCPCS Code G2012 the following requirements must be met:
- Real-time audio communication via phone call or other mechanisms, including two-way audio interactions that are enhanced with the video or other kinds of data transmission.
- Communication with the patient needs to have a minimum duration of five minutes
- The billing clinician must be eligible to bill for Medicare evaluation and management encounters
- G2012 is only applicable to established patients, following the same guidance as ambulatory E/M coding i.e., the patient is considered established if they have been seen by a clinician in the same subspecialty that has provided face-to-face E/M services to the patient in the past three years.
- The patient must provide verbal consent during the communication, acknowledging that they are responsible for the 20% co-pay. This needs to be documented in the record for the encounter. Written consent from the patient is not required.
- The communication between the patient and clinician cannot be linked to a prior evaluation and management visit that occurred in the past seven days.
- The phone call or audiovisual communication cannot result in an office visit including evaluation and management service or procedure within 24 hours of the communication or the soonest available appointment.
- There is no limit on the number of times a service can be used for an individual patient.
- Documentation must support the medical necessity of the communication.
- The communication should, in general, be initiated by the patient.
In summary, newly approved Medicare HCPCS code G2012 will be useful to clinicians that have frequent telephonic or other types of audio communications with patients that do not lead directly to E/M encounters. An example provided by CMS would be phone calls with patients as part of a treatment regimen for opioid or other substance use disorders to assess the need for a face-to-face office visit.
Patients are responsible for the 20% co-pay, which will amount to approximately two dollars per audio encounter. However, the clinician is obligated to inform the patient that they will be billed for the communication in the clinician must document that consent was obtained. This may create challenges for clinicians that feel uncomfortable discussing payment terms with patients that need medical or mental health advice and counseling. Code G2012 has relatively low reimbursement, but prior to 2019 clinicians were receiving no reimbursement for these types of encounter.
Addendum: Summary of Documentation Requirements for HCPCS code G2012
- Confirm patient identity (e.g., name, date of birth or other identifying information as needed, in particular if documenting independently from the patient’s electronic or paper record).
- Confirm that the patient is an established patient to the practice (based on the requirements above)
- Detail what occurred during the communication (e.g., patient problem(s), details of the encounter as warranted) to establish medical necessity
- Document the total amount of time spent in communicating with the patient and only submit code G2012 if a minimum of five minutes of direct communication with the patient was achieved.
- Document that the nature of the call was not tied to a face-to-face office visit or procedure that occurred within the past seven days
- Document that a subsequent office visit for the patient’s problems were not indicated within 24 hours or the next available appointment
- Include that the patient provided consent for the service
For questions or additional information please contact the author (Michael Stearns, MD, CPC, CFPC) at Michael@ApolloHIT.com