CMS will now pay clinicians to remotely check in on patients in lieu of an office visit

In its Final Rule for the 2019 Medicare Physician Fee Schedule released on Friday, CMS introduced a new code, HCPCS G2012, allowing physicians and other qualified healthcare professionals (“QHCPs”) to be reimbursed for “virtual check-ins” with patients who aren’t sure whether or not their symptoms warrant an in-office visit. These virtual check-ins may be “audio-only” (e.g., a telephone call between the patient and the QHCP) or live two-way audio with video “or other kinds of data transmission.” If the check-in does not lead to an in-office visit and does not occur within seven days of a prior E/M service by the billing practitioner, it may be billed as a standalone service.

Who can bill HCPCS Code G2012?

HCPCS G2012 can be billed by both primary care and specialty practitioners, and the commentary to the rule suggests it could be used as part of a treatment regimen for opioid use disorders and other substance use disorders to assess whether the patient’s condition requires an office visit.  The finalized code descriptor reads as follows:

 HCPCS G2012: Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.

What you need to know about HCPCS Code G2012

Starting January 1, 2019, a physician or QHCP may bill for a virtual check-in with HCPCS Code G2012. In doing so, it is important to keep the following parameters set forth in the rule in mind:

  1. Established Patients. The patient on the other end of the check-in must be an “established patient” of the billing physician/QHCP. The rule defines an established patient as one who has received professional services within the past three years from the physician or qualified health care professional or another physician or qualified health care professional of the exact same specialty and subspecialty who belongs to the same group practice.

  2. Billing Practitioner. The new code explicitly requires direct interaction between the patient and the billing practitioner. It is NOT billable if the evaluation is performed by clinical staff or a practitioner not qualified to furnish E/M services. (Note: in contrast, CCM codes CAN be billed for check-ins provided by nurses and other clinical staff, and can be billed concurrently with G2012 if the patient qualifies for such codes.)

  3. Copayments. As with other Medicare Part B services, the patient is responsible for a copayment for each billed service.

  4. Consent and Documentation. Verbal consent by the patient for each virtual check-in must be documented in the medical record.  There is, however, no service-specific documentation requirement.

  5. Timing of In-person Visit. If the virtual check in (i) takes place within seven (7) days after an in-person visit, or (ii) triggers an in-person office visit within twenty-four 24 hours (or the soonest available appointment), the service is NOT billable, and its payment is considered bundled into the relevant in-office E/M code.

  6. Frequency. There is no frequency limitation on the use of the code by the same practitioner with the same patient. However, the billing practitioner should be mindful that each service must be medically reasonable and necessary to qualify for payment by Medicare. 


READ MORE ABOUT THE 2019 FEE SCHEDULE CHANGES RELATED TO Remote Evaluation of Patient-Submitted Video and Images, Virtual Physician Consults, RPM and Chronic Care Remote Patient Monitoring, or contact Nixon Law Group for a consultation on how we can help you take advantage of these new reimbursement opportunities.