CMS Clarifies Billing of Communication-Technology Based Services in Annual Therapy Code Update

CMS Clarifies Billing of Communication-Technology Based Services in Annual Therapy Code Update

On December 31, 2020, CMS published MedLearn Matters article MM12126 which updates the list of CPT/HCPCS codes that “sometimes” or “always” describe therapy services. In this article, CMS clarifies that e-visits, virtual check-ins, and remote assessment of recorded video/images (i.e., communication technology-based services or CTBS) can be rendered and billed on a permanent basis by PTs, OTs and SLPs in both private practice AND institutional settings. You may recall that in the 2021 Physician Fee Schedule final rule, CMS referred to therapists in “private practice” as able to bill these services, apparently leaving out institutional providers (i.e., those that bill on a UB-04). This article confirms that institutional providers such as therapists working in hospital outpatient departments, skilled nursing facilities, rehab agencies, and home health agencies may render and bill CTBS on a permanent basis, even after the COVID-19 public health emergency ends.

In the 2021 final rule, CMS finalized the creation of two new HCPCS codes for therapists (and other providers who do not bill E/M services) to represent virtual check-ins and remote assessment of recorded video/images – G2251 (replaces G2012) and G2250 (replaces G2010). In addition, CMS clarified in the final rule that HCPCS codes G2061, G2062 and G2063 are replaced by CPT codes 98970, 98971 and 98972 effective 1/1/2021.

For more information, access MM12126 here.

Holly Hester

Holly Hester is Casamba’s Senior Vice President of Compliance & Education, as well as the Compliance Officer. She provides regulatory guidance and interpretation, clinical programming and content development, education and training steerage, and compliance support for the company. As a physical therapist for more than 20 years, Holly has multi-venue clinical and management experience, giving her a unique perspective on the integration of compliance and training with therapy service delivery and clinical practice.
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