Not considered telehealth
CMS developed two new codes for 2019 to pay a very small amount of money for a virtual check-in and for reviewing an image or recording, “store and forward.” They are HCPCS codes G2010 and G2012.
CMS said it doesn’t consider these to be telehealth services, although they are using “technology-based” and so they don’t need to meet the requirements of telehealth.
G2012 brief communication technology-based virtual check-in
Let me start with this. What technology can be used for this technology-based check-in?
Well, it includes the telephone. I’m not kidding you. Here’s a quote from the 2019 Final Rule:
“We are persuaded by the comments advising us not to be overly prescriptive about the technology that is used, and are finalizing allowing audio-only real-time telephone interactions in addition to synchronous, two-way audio interactions that are enhanced with video or other kinds of data transmission. We note that telephone calls that involve only clinical staff could not be billed using HCPCS code G2012 since the code explicitly describes (and requires) direct interaction between the patient and the billing practitioner.”
The service could be performed using more advanced technology, such as a patient portal or a HIPAA compliant video service. But, burying the lede here, they are allowing telephone!
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