Grant Huang
This auditing and compliance “Tip of the Week” was originally published by the National Alliance for Medical Auditing Specialists (NAMAS), a division of DoctorsManagement.

The recent coronavirus crisis has brought non-face-to-face services to the forefront of coding and billing conversations. With the entire healthcare industry focused on caring for patients during an unprecedented and fast-moving pandemic, the goal of increasing patient access while reducing the risk of spreading infection has become paramount.

In this climate, non-face-to-face services are poised to flourish. In this tip, we will examine a relatively new code series, introduced in 2019, called interprofessional telephone/Internet assessment and management service.

These services represent an electronic discussion between a patient’s treating (e.g., attending or primary) physician and another physician with specific specialty expertise (i.e. the consultant). The purpose of this interprofessional encounter is for the consultant to assist the treating physician or other qualified healthcare provider in the diagnosis and/or management of the patient’s problem without patient face-to-face contact with the consultant. The patient is not involved in this service beyond giving verbal consent. CMS will allow verbal consent to be collected once annually starting in 2020, for interprofessional consults and other communications technology-based services (CTBS). Alternatively, the provider may obtain verbal consent at each encounter and document that consent for each encounter. These services are subject to the following requirements per CPT:

  • The patient may be either a new or established patient to the consultant, but this service is not billable if consultant has seen the patient face-to-face within the last 14 days.
  • When the online consultation leads to a transfer of care or other face-to-face service (e.g., a surgery, a hospital visit, or a scheduled office evaluation of the patient) within the next 14 days or next available appointment date of the consultant, these codes are not billable.
  • Review of pertinent medical records, laboratory studies, imaging studies, medication profile, pathology specimens, etc. is included in this consultation and not reported separately. The majority of the service time reported (greater than 50%) must be devoted to the medical consultative verbal or Internet discussion. If greater than 50% of the time for the service is devoted to data review and/or analysis, report 99451, which is based on total review and discussion time rather than discussion time alone.
  • Only one interprofessional consultation code is reportable within a seven-day interval.
  • The written or verbal request for the consultation must be documented in the patient’s medical record, including the reason for the request. Codes 99446, 99447, 99448, 99449 require a verbal opinion report and written report from the consultant to the requesting provider. Code 99451 requires only a written report.
  • Interprofessional consultations of less than five minutes should not be reported.
  • The treating/requesting provider may report 99452 if 16-30 minutes is spent preparing for the referral and/or communicating with the consultant. This code is billable once every 14 days.Interprofessional Online Consults Coding
    • 99446: Interprofessional telephone/Internet/EHR assessment and management service provided by a consultative physician, including a verbal and written report to the patient’s treating/requesting physician or other qualified health care professional; 5-10 minutes of medical consultative discussion and review.
    • 99447: 11-20 minutes of medical consultative discussion and review.
    • 99448: 21-30 minutes of medical consultative discussion and review.
    • 99449: 31 minutes or more of medical consultative discussion and review.
    • 99451: Interprofessional telephone/Internet/EHR assessment and management service provided by a consultative physician, including a written report to the patient’s treating/requesting physician or other qualified health care professional, 5 minutes or more of medical consultative time.
    • 99452: Interprofessional telephone/Internet/EHR referral service(s) provided by a treating/requesting physician or other qualified health care professional, 30 minutes.

    Coding and Documentation Advice
    Remember to document patient’s verbal consent, either per consultation in the medical record, or by obtaining an annual CTSB consent using a standard consent form, modified to indicate it is for communications technology services. Because these are time-based codes, ensure the provider documents the total service time and that they also distinguish between discussion and review time. Discussion time refers to a conversation between the consulting and requesting providers. Review time refers to time spent by the consulting provider on reviewing all applicable records and data.

This Week’s Audit Tip Written By:
Grant Huang
Grant is the Director of Content for our parent company, DoctorsManagement

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