New for 2020!
- CPT® developed three new CPT® codes for use by physicians, physician assistants and advanced practice nurse practitioners performing brief, online E/M services via a secure platform
- CMS is developing three new HCPCS codes for use by clinicians who do not have E/M within their scope of practice who have E/M services in their scope of practice, and will recognize these instead of new CPT® codes 98970—98792
New CPT® codes and CMS payment
In the 2020 CPT® book, CMS is deleting code 99444, which was defined as an online E/M service by a physician or other qualified health care professional. CPT® is adding three new time-based codes for online evaluation and treatment, for use by clinicians who have E/M in their scope of practice. 99444 was never paid by Medicare or most insurance companies.
New CPT® codes for online digital E/M
99421 Online digital evaluation and management service, for an established patient, for up to 7 days cumulative time during the 7 days; 5-10 minutes
99422 11—20 minutes
99423 21 or more minutes
These codes are for use when E/M services are performed, type that would be done face-to-face, are performed through a HIPAA compliant secure platform. These are for patient-initiated communications, and may be billed by clinicians who may independently bill an E/M service. They may not be used for work done by clinical staff or for clinicians who do not have E/M services in their scope of practice.
Report these services once during a 7-day period, for the cumulative time. According to CPT®,
“The seven-day period begins with the physician’s or other qualified health care professional’s (QHP) initial, personal review of the patient-generated inquiry. Physician’s or other QHP’s cumulative service time includes review of the initial inquiry, review of patient records or data pertinent to assessment of the patient’s problem, personal physician or other QHP interaction with clinical staff focused on the patient’s problem, development of management plans, including physician or other QHP generation of prescriptions or ordering of tests, and subsequent communication with the patient through online, telephone, email, or other digitally supported communication, which does not otherwise represent separately reported E/M service.”
- The interaction must be documented in the permanent record.
- If within seven days of the initiation of the online service a face-to-face E/M service occurs, then the time of the online service or decision-making complexity may be used to select the E/M service, but this service may not be billed.
- If the patient initiates this online service within seven days after an E/M service for the same problem, these codes may not be billed.
- If the patient inquiry is within seven days of an E/M service for a new problem, the online service may be reported.
- This is for established patients, per CPT®.
- This may not be billed by surgeons during the global period.
- The digital service must be provided via a HIPAA compliant platform, such as an electronic health record portal, secure email or other digital applications.
- These services may only be reported once in a 7-day period.
- Clinical staff time may not be included.
- Don’t double count time with any other separately reported services, such as care management, INR monitoring, remote monitoring. (CPT® book has a list of codes)
Online services provided by clinicians who may not bill E/M services
CPT® also developed codes for us by other professionals, eg, “speech-language pathologists, physical therapists, occupational therapists, social workers, dieticians.” Medicare, however, is not recognizing these codes, 98970, 98971, 98972, because their definition includes the word “evaluation” and Medicare reserves that word for physicians and NPPs who can perform E/M services. Medicare is proposing HCPCS codes for use by these clinicians. These are dummy codes from the Proposed Rule. If CMS adopts these, they will develop HCPCS codes for them for 2020. Medicare is developing these HCPCS codes
“Dummy” HCPCS codes—actual codes will be released in November, 2019.
GNPP1(Qualified non-physician health care professional online assessment, for an established patient, for up to seven days, cumulative time during the 7 days; 5-10 minutes);
GNPP2 11-20 minutes
GNPP3 21 or more minutes
|Code||Description||Work RVU’s||Non-facility proposed fee 2020||Facility proposed fee 2020|
|99421||Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes||0.25||15.52||13.35|
|99423||21 or more minutes||0.8||49.8||43.31|
|GNPP1||(Qualified non-physician health care professional online assessment, for an established patient, for up to seven days, cumulative time during the 7 days; 5-10 minutes);||0.25||12.27||12.27|
|GNPP3||21 or more minutes||0.69||34.29||33.92|
 CPT Professional Edition, 2020. AMA, Chicago, p. 68.
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