Medicare telehealth benefit adds three psychotherapy codes for 2015
Three services provided by psychologists — psychoanalysis (90845), family psychotherapy without patient present (90846) and family psychotherapy (conjoint therapy) with patient present (90847) — are newly eligible as of Jan. 1, 2015, for Medicare reimbursement under the telehealth benefit. Psychologists who provide services to a Medicare beneficiary located at an “originating site” can bill for these services delivered by telehealth.
Medicare will cover telehealth services that mimic normal face-to-face interactions between beneficiaries and their health care providers. The federal health care program will only pay for "face-to-face," interactive video consultation services where the patient is present at an eligible originating site and the psychologist or other provider is at a distant site.
The Centers for Medicare and Medicaid Services (CMS) requires that the telehealth interaction use real-time audio and video communications between the patient and provider. Telephones, facsimile (fax) machines and electronic mail systems do not meet the definition of an interactive telecommunications system.
Further, free videoconferencing platforms like Skype may be problematic as they may not be consistent with the Health Insurance Portability and Accountability Act (HIPAA). Practitioners should consider using a platform that is HIPAA-compliant and offers a business associate agreement. Asynchronous “store and forward” technology is permitted only in federal telemedicine demonstration programs conducted in Alaska or Hawaii.
An “originating site” is where the patient is located at the time the telehealth service is being furnished via a telecommunications system. Medicare beneficiaries are eligible for telehealth services only if they are at an originating site located in:
- A rural Health Professional Shortage Area, either located outside of a Metropolitan Statistical Area (MSA) or in a rural census tract, as determined by the Office of Rural Health Policy within the Health Resources and Services Administration (HRSA).
- A county outside of a MSA.
The Health Resources and Services Administration of the U.S. Department of Health and Human Services has an online tool for determining whether an originating site is eligible for telehealth reimbursement under Medicare.
The originating sites (where the patient must be) authorized by law are:
- The offices of physicians or practitioners.
- Critical access hospitals (CAH).
- Rural health clinics.
- Federally qualified health centers.
- Hospital-based or CAH-based renal dialysis centers (including satellites).
- Skilled nursing facilities (SNF).
- Community mental health centers (CMHC).
Providers at the distant site who may furnish and receive payment for covered telehealth services (in accordance with state law) are:
- Clinical psychologists (CP).
- Psychiatrists and other physicians.
- Nurse practitioners (NP).
- Clinical social workers (CSW).
- Physician assistants (PA).
- Clinical nurse specialists (CNS).
- Registered dietitians or nutrition professionals.
As in the outpatient office setting, psychologists can bill the following codes for telehealth:
- 90791 psychiatric diagnostic evaluation.
- 90832 psychotherapy, 30 minutes.
- 90834 psychotherapy, 45 minutes.
- 90837 psychotherapy, 60 minutes.
- 96116 neurobehavioral status examination.
- 96150 health and behavior assessment, face-to-face, 15 minutes.
- 96151 health and behavior reassessment, face-to-face, 15 minutes.
- 96152 health and behavior intervention, face-to-face, 15 minutes, individual.
- 96153 health and behavior intervention, face-to-face, 15 minutes, group of 2 or more.
- 96154 health and behavior intervention, face-to-face, 15 minutes, family with patient present
Effective on or after Jan. 1, 2015, three more services will be added to the telehealth benefit:
- 90845 psychoanalysis.
- 90846 family psychotherapy, without patient present.
- 90847 family psychotherapy (conjoint therapy), with patient present.
Telehealth services do not have separate billing codes. Rather, the provider at the distant site who furnished services via telehealth submits claims using the appropriate code for the service provided along with the “GT” modifier indicating that the service was provided via interactive audio and video telecommunications. The originating site may bill for the facility fee using the HCPCS code — Q3014 — telehealth originating site facility fee.
For more information
An online fact sheet from CMS (PDF, 928KB) provides details about the 2014 Medicare telehealth benefit. Further, the Health Resources and Services Administration offers a publication about reimbursement issues related to telehealth.