HCPCS Code G2010 opens the door for new payments to PCPs, Dermatologists, and other Qualified Healthcare Providers who interpret still or video images sent electronically by patients.

The final 2019 Medicare Physician Fee Schedule, released by CMS on November 1, 2018, includes a new code that physicians may use to bill for remote evaluation of images to determine whether or not an in-person office visit is necessary. If this evaluation 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 for remote evaluation of images?

HCPCS Code G2010 should prove especially useful in specialty practices where evaluation of a patient’s current condition is aided by still and/or video images transmitted by the patient to his or her physician. Obvious examples include Dermatology and Ophthalmology, but use cases might also include Endocrinology, Infectious Disease, and even Primary Care practices.

The final code descriptor for HCPCS Code G2010 reads as follows: 

HCPCS G2010: Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, 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

What you need to know about HCPCS Code G2010

Starting January 1, 2019, physicians and other Qualified Healthcare Providers (“QHCPs”) can bill HCPCS Code G2010 under the circumstances below.  Note that these parameters are very similar to those established for billing HCPCS Code G2012 for Virtual Check-ins.  

  1. Established Patients. The patient whose still image(s) and/or video is being evaluated must be an “established patient” of the billing physician or QHCP.  An established patient is defined as one who has received professional services from the physician or qualified health care professional (or another physician or QHCP of the exact same specialty and subspecialty who belongs to the same group practice) within the past 3 years.

  2. Billing Practitioner. The new code does not dictate what type of practitioner can bill for evaluating the image. However, HCPCS G2010 is NOT billable if the evaluation is performed by clinical staff or a practitioner not qualified to furnish E/M services.

  3. Consent and Documentation. Advance consent from the patient must be obtained verbally or electronically, and must be documented in the medical record. There is no specific requirement for service-level documentation.

  4. Copayment. A practice must collect the requisite copayment from the patient for each service billed, as with all Medicare Part B services.

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

  6. Patient Follow-Up. The code requires follow-up by the practitioner with the patient based on the evaluation of the still or video image(s) in the form of a 5-10 minute discussion with the patient.

Understanding the details of these requirements is critical to implementing a successful and compliant remote patient monitoring program. For assistance, please contact Nixon Law Group.


READ MORE ABOUT THE 2019 FEE SCHEDULE CHANGES RELATED TO Virtual Check Ins, 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.