Coding decisions are personal choices to be made by individual oral and maxillofacial surgeons exercising their own professional judgment in each situation. The information provided to you in this article is intended for educational purposes only. In no event shall AAOMS be liable for any decision made or action taken or not taken by you or anyone else in reliance on the information contained in this article. For practice, financial, accounting, legal or other professional advice, you need to consult your own professional advisers. CPT® only © 2020 American Medical Association Current Dental Terminology® (CDT) © 2020 American Dental Association. All rights reserved.
Telehealth services consist of using various tools and/or modes to deliver healthcare services or health education from a distance. Telemedicine is the practice of medicine using technology to deliver care at a distance. Teledentistry is the use of information technology and telecommunications for dental care, consultation, education and public awareness.
Telehealth (telemedicine) consists of various tools and/or modes delivering healthcare services or health education from a distance, such as:
- Live video chat (synchronous) – live, two-way interaction between a person (patient, caregiver or provider) and a provider using audiovisual telecommunications technology.
- Store-and-forward (asynchronous) – transmission of radiographs, photographs, video or digital impressions through a secure electronic communications system to a practitioner. This information is then used to diagnose or provide a service.
- Remote patient monitoring (RPM) – collecting personal health and medical data from a single individual via electronic medical device technologies. The data are transmitted to a different location (sometimes via a data processing service) where the provider can access the data for monitoring conditions and supporting care delivery.
- Mobile health (mHealth) – healthcare education, practice and delivery done over mobile communication devices, such as cellphones, tablet computers and personal digital assistants (PDAs).
As a result of the COVID-19 pandemic, the U.S. Department of Health and Human Services (HHS) has deemed applications such as Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, WhatsApp video chat, Zoom and Skype as acceptable services of communication for telehealth.
HHS has advised that public-facing apps – such as Facebook Live, Twitch and TikTok – should not be used in the provision of telehealth by covered healthcare providers. The AAOMS telehealth page has links to updated HHS privacy directives.
Currently, AAOMS does not offer a telehealth service recommendation. However, you may wish to follow up with your own software vendor, which may have the capability to conduct telehealth services. OMSVision, for example, has recently reported adding a telehealth feature to its software.
You also may search the AAOMS Supplier Marketplace for other vendors that may offer the service. One supplier, AdvancedMD, reports it offers telemedicine options.
You may check with your malpractice insurance carrier to ensure your policy covers providing care via telemedicine and whether there are additional consent requirements. The AMA has provided guidance during the pandemic.
The Department of Health and Human Services (HHS) and the Office for Civil Rights (OCR) issued updated guidance regarding HIPAA and use of telecommunication technology during the COVID-19 public health emergency.
The following are services that may possibly be rendered via telehealth. CPT defines the following services as:
Telephone services – These are non-face-to-face E/M services using the telephone when initiated by an established patient. If the telephone service ends with a decision to see the patient within 24 hours or at the next urgent care appointment, it is not to be reported. It also is not to be reported if the telephone service is related to an E/M service seven days prior or within the postoperative period of a previously completed procedure.
Online digital E/M services (e-visits) – These codes took effect Jan. 1, 2020, and may be used when rendering a digital evaluation for an established patient who initiates the digital evaluation by sending the OMS a message detailing his or her concerns via a patient portal, secure email or other electronic communication that is HIPAA compliant.
Interprofessional telephone/internet/electronic health record consultations – These represent an assessment and management service in which the patient’s treating physician or other qualified healthcare professional requests the opinion and/or treatment advice of a physician with specific specialty expertise to assist the treating physician or other qualified healthcare professional in the diagnosis and/or management of the patient’s problem without face-to-face contact with the consultant.
CMS also posts a list of telehealth services payable under the Medicare Physician Fee Schedule. It is recommended to contact commercial payers to verify what services they are currently covering.
Any questions regarding malpractice insurance should be addressed with your malpractice attorney. OMSNIC has posted helpful FAQs at OMSNIC.com/COVID19.
Several CPT and CDT codes may be reported for conducting “virtual” evaluations and/or treatment advice to your patients. Both CPT and CDT have released specific guidelines for the use of these codes.
Prior to using these codes, it is imperative you refer to your coding books for complete guidance. Both the AMA and ADA continue to issue coding guidance for use of telehealth codes, including practice implementation tips, coverage and policy summaries and example coding scenarios. The ADA also provides a series of FAQs to better assist with inquiries regarding billing and coding. It is important to refer to coding manuals for appropriate use and complete coding guidance.
It also is important to note that payer coverage and payment criteria may vary. While CMS lifted restrictions on the originating site of the telehealth service, some commercial payers may still apply limitations as to the originating site of the telehealth service, so you also will need to review the patient’s benefit language and/or the carrier’s coverage criteria to determine coverage.
You also must review your provider contracts to determine whether you may bill the patient in the event it is denied. Lastly, state laws concerning carrying out telehealth and teledentistry may vary, so you will want to confirm with your state dental and medical boards to determine if/when appropriate to render telehealth services in your practice.
This may vary depending on the service and code selected. Some payers restrict from billing if a face-to-face visit was rendered 14 days prior to the televisit or results 14 days after the televisit.
Coverage and reimbursement may vary among insurance carriers. Some insurance carriers are waiving copays and deductibles, while others are waiving the need for prior authorization. Some plans will cover the costs of diagnostic testing and/or services related only to COVID-19. Therefore, it is recommended to contact the carrier to verify its policy on telehealth/telemedicine.
America’s Health Insurance Plans and the ADA have compiled a summary of how commercial payers have responded with policy changes stemming from the public health crisis:
In efforts to increase cash flow to providers impacted by COVID-19, CMS and some dental payers have stepped forward to extend temporary payment relief as many experience significant disruption in claims submissions and payment.
CMS has extended its current Accelerated and Advance Payment Program to a broader group of Medicare providers for the duration of the public health emergency. Similarly, Delta Dental in several states also has instituted advance payment programs to assist providers participating in their networks.
It is unknown if other payers are implementing similar programs at this time. It is best to inquire with your provider representatives at each of the payers with which you participate.
Both the ADA and CMS have issued guidance on what they deem to be emergent and/or urgent services. States also are continuing to issue their own recommendations on what constitutes an emergency. Check your local laws and/or directives. View AAOMS daily state-by-state updates.
Coding for dental emergencies should be coded and treated the same way as before the current health crisis. You may bill medical and/or dental only if the procedure applies to both. Two CDT codes may be considered. However, the ADA’s Coding Companion states not all dental plans will cover these codes; therefore, contractual obligations may apply:
- D9440 for office visit after regularly scheduled hours OR
- D9430 for office visit for observation (during regularly scheduled hours – no other services performed)
Some states have laws that may prohibit balance billing by a non-participating provider in an emergency. Also, some states have defined what is considered an emergency during the pandemic.
When billing for any type of telehealth visit, it is recommended to indicate the intent and circumstance of the visit and report the most appropriate code(s) based on documentation. Note: Global period rules still apply as do the previously mentioned coding guidelines.
The ADA has released an online course covering Teledentistry in the Era of COVID-19. Teledentistry experts Dr. Paul Glassman and Nathan Suter review reliable sources of information about telehealth and telemedicine relating to dentistry, including HIPAA waivers.
CMS also released a video providing answers to common questions about the Medicare telehealth services benefit. CMS is expanding this benefit on a temporary and emergency basis under the 1135 waiver authority and Coronavirus Preparedness and Response Supplemental Appropriations Act.
On April 30, CMS issued a second interim final rule expanding telehealth visits to phone calls. Providers can now be reimbursed for phone calls at the E/M office/outpatient rates by reporting 99441-99443 along with modifier 95 and the POS in which the service would normally be furnished. OMSs should follow up with their payers to determine if a similar benefit will be considered.