Coding changes to Medicare telehealth services for CY 2024

© Andrey Popov - stock.adobe.com

Q: We are a primary care office and need to make sure we know the changes to the telehealth services next year (2024) applicable to us.

A: Medicare has several important updates to telehealth services for 2024, and those that are most pertinent to primary care are included here.

New codes

These codes are being added to the list of Medicare telehealth services.

• CPT codes 0591T - 0593T for health and well-being coaching services (temporarily added)

• HCPCS code G0136 for Social Determinants of Health Risk Assessment (permanently added)

For code G0136, it’s important to remember that it must be provided in conjunction with a qualifying visit, (i.e., an E/M visit, some behavioral health visits or the Annual Wellness Visit). When choosing the required evidence-based, standardized Social Determinants of Health (SDOH) risk assessment tool, make sure that it covers (at a minimum) housing insecurity, food insecurity, transportation needs and utility difficulty.

Evaluation and management (E/M) visits

Complexity add-on HCPCS Code G2211 – Medicare will reimplement this code starting January 1, 2024, recognizing that separately identifiable visits occurring on the same day as minor procedures (such as zero-day global procedures) have resources that are sufficiently distinct from the costs associated with providing stand-alone office or outpatient E/M visits to warrant different payment. An important caveat to this is that G2211 won’t be payable when an office E/M visit is billed with modifier 25.

Hospital telehealth services – Starting in CY 2024, the Centers for Medicare and Medicaid Services (CMS) telehealth services provided to people in their homes will be paid at the non-facility PFS rate, and modifier '95' should be used when the clinician is in the hospital and the patient is in the home.CMS is also allowing teaching physicians to use audio or video technology when a resident provides Medicare telehealth services through the end of CY 2024.Additionally, frequency limitations are removed in 2024 for subsequent inpatient visits, subsequent nursing facility visits and critical care consultations.

Medicare has solidified the definition of “substantive portion” for Split/Shared E/M visits in the hospital and other institution settings.For Medicare billing purposes, the “substantive portion” means more than half of the total time spent by the physician or non-physician practitioner performing the split/shared visit, or a substantive part of the medical decision making.

DSMT (Diabetes Self-Management Training) services provided by registered dietitians (RDs) and nutrition professionals

CMS has amended the 2022 guidance that a RD or nutrition professional must personally perform MNT services.In 2024, enrolled RD or nutrition professional may bill for, or on behalf of, the entire DSMT entity as the DSMT certified provider, regardless of which professional personally delivers the service.

Caregiver training

For CY 2024, Medicare is finalizing new coding (CPT codes 96202, 96202, 97550, 97551, and 97552) to make payment when practitioners train and involve one or more caregivers to assist patients with certain diseases or illnesses (such as dementia) in carrying out a treatment plan. These services will be paid when performed by a physician or a NPP (nurse practitioners, CNSs, certified nurse-midwives, PAs, and clinical psychologists), or therapist (PT, OT, or SLP) under an individualized treatment plan or therapy plan of care, without the patient present.

The following provisions are also being implemented as of January 1, 2024:

• Temporarily, CMS is expanding the telehealth originating sites to include to include any site in the U.S. where the patient is at the time of the telehealth service, including a person’s home.
• Qualified occupational therapists (OTs), physical therapists (PTs), speech-language pathologists (SLPs), and audiologists can provide telemedicine visits.
• CMS is delaying the requirement for an in-person visit with the physician or practitioner within 6 months prior to initiating mental health telehealth services, and again at subsequent intervals, as well as similar requirements for RHCs and FQHCs.
• Through December 31, 2024, CMS will continue to cover the services on the 2020 Medicare Telehealth Services List
• Adding mental health counselors (MHCs) and marriage and family therapists (MFTs) as distant site practitioners for purposes of providing telehealth services

Please refer to MM13452 - Medicare Physician Fee Schedule Final Rule Summary: CY 2024 (hhs.gov) for full details.

Renee Dowling is a compliance auditor at Sansum Clinic, LLC, in Santa Barbara, California.