E-Visits, Telehealth and MIPS Billing Updates

Author: Paul Singh


The updates below are current as of March 23, 2020.

  1. E-visit codes (G2061-G2063) cannot be billed within 7 days, before or after a face-to-face visit.
  2. All communication within the 7 day time period should be clearly noted in your documentation.  At the end of the 7 day time period, you will bill the e-visit code that reflects the cumulative time spent communicating with the patient. 
  3. An e-visit is not a “visit” as we typically define it, nor is it the same as telehealth.  It is a brief digital communication that allows a therapist to answer a patient’s questions.
  4. Since e-visits are not considered telehealth, visual interaction, including FaceTime and Skype, are not recommended methods to communicate with patients.  In lieu of a patient portal, APTA advised a telephone call would be the most appropriate method of communication.
  5. As clinical decision-making is involved, therapy assistants are not permitted to perform e-visits.
  6. The APTA is currently pending clarification from CMS as to whether or not you can bill an e-visit again during the same episode of care.  Until confirmation can be provided, the APTA recommends that an e-visit is only billed once for each patient.
  7. E-visits will not count towards the annual therapy cap, nor will a KX modifier be used for these codes.
  8. IMPORTANT MIPS UPDATE: CMS announced relief for clinicians reporting in the MIPS program in response to COVID-19.   They have extended the deadline to report by 30 days to April 30, 2020. CMS also stated the following, “MIPS eligible clinicians who have not submitted any MIPS data by April 30, 2020 do not need to take any additional action to qualify for the automatic extreme and uncontrollable circumstances policy. These clinicians will be automatically identified and receive a neutral payment adjustment for the 2021 MIPS payment year. All four MIPS performance categories for these clinicians will be weighted at zero percent, resulting in a score equal to the performance threshold, and a neutral MIPS payment adjustment for the 2021 MIPS payment year. However, if a MIPS eligible clinician submits data on two or more MIPS performance categories, they will be scored and receive a 2021 MIPS payment adjustment based on their 2019 MIPS final score.”

We will continue to provide you with additional details as they become available.  We understand it can be very challenging to keep up with the rapidly changing billing guidelines.  Please know that we are focusing on all of these details so you can continue to focus on your patients and practice.

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