AMA: Special coding advice during COVID-19 public health emergency

3 Big Changes with the April 3, 2020 Update:

1. Place of Service (POS) Claims. The AMA revised its guidance to align with CMS’ new guidance related to place of service (POS) on claims.  The place of service should not be 02 during this global pandemic as previously directed.  Healthcare organizations should instead report the POS for the Physician Office or other applicable site of the practitioner’s normal office location.
2. Modifier 95. The AMA revised its guidance to align with CMS’ new guidance that requires use of modifier -95 for telehealth services.
3. New Clinical Coding Examples. Additional clinical coding examples have been added to the policy, including coding of telehealth visits for patients in the emergency department, observation, or inpatient status.

The coding scenarios in this document are designed to apply best coding practices. The American Medical Association (AMA) is working to ensure that all payors are applying the greatest flexibility to our physicians in providing care to their patients during this public health crisis.

• The Centers for Medicare & Medicaid Services (CMS) lifted Medicare restrictions on the use of telehealth services during the COVID-19 emergency. Key changes include:
  • Effective March 6 and throughout the national public health emergency, Medicare will pay physicians for telehealth services at the same rate as in-person visits for all diagnoses, not just services related to COVID-19.
  • Patients can receive telehealth services in all areas of the country and in all settings, including at their home.
  • CMS will not enforce a requirement that patients have an established relationship with the physician providing telehealth.
  • Physicians can reduce or waive cost-sharing for telehealth visits.
  • Physicians licensed in one state can provide services to Medicare beneficiaries in another state. State licensure laws still apply.
• HHS Office for Civil Rights offers flexibility for telehealth via popular video chat applications, such as FaceTime or Skype, during the pandemic.
• AMA’s telemedicine quick guide has detailed information to support physicians and practices in expediting implementation of telemedicine.
• Disclaimer: Information provided by the AMA contained within this Guide is for medical coding guidance purposes only. It does not (i) supersede or replace the AMA’s Current Procedural Terminology® manual (“CPT Manual”) or other coding authority, (ii) constitute clinical advice, (iii) address or dictate payer coverage or reimbursement policy, and (iv) substitute for the professional judgement of the practitioner performing a procedure, who remains responsible for correct coding.
• To learn more about CPT licensing click here.

To view all scenarios, actions and respective codes, view the full AMA guide here.