UPDATE: Read our post on the changes to Remote Patient Monitoring in the 2020 Proposed Medicare Physician Fee Schedule HERE.
CPT Codes 99446-99449, 99451, and 99452 now provide standalone reimbursement for “Interprofessional Internet Consultation”
The final 2019 Medicare Physician Fee Schedule (the “Rule”), released on November 1st, unbundles four existing codes (CPT Codes 99446-99449) and creates two new codes (CPT Codes 99451 and 99452) in the category of Interprofessional Internet Consultation. In CMS’ words:
The six codes describe assessment and management services conducted through telephone, internet, or electronic health record consultations furnished when a patient’s treating physician or other qualified healthcare professional requests the opinion and/or treatment advice of a consulting physician or qualified healthcare professional with specific specialty expertise to assist with the diagnosis and/or management of the patient’s problem without the need for the patient’s face-to-face contact with the consulting physician or qualified healthcare professional.
CMS’ decision to unbundle the existing codes increases efficiency for patients and providers, eliminating the need for separate, costly, and inconvenient specialist appointments where a phone or internet-based interaction between the treating physician (or qualified healthcare professional) and consulting physician with specific expertise is sufficient. Additionally, the two new CPT codes add reimbursement not previously available for the treating provider’s efforts in initiating the consult.
What are the Interprofessional Internet Consultation codes?
The final code descriptors for Interprofessional Internet Consultations are as follows:
CPT 99446: Interprofessional telephone/Internet 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
CPT 99447: Same as 99446, but 11-20 minutes of medical consultative discussion and review
CPT 99448: Same as 99446, but 21-30 minutes of medical consultative discussion and review
CPT 99449: Same as 99446, but 31 minutes or more of medical consultative discussion and review
CPT 99451: Interprofessional telephone/Internet/electronic health record 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 or more minutes of medical consultative time
CPT 99452: Interprofessional telephone/Internet/electronic health record referral service(s) provided by a treating/requesting physician or qualified health care professional, 30 minutes
What you need to know about Interprofessional Internet Consultations
Beginning January 1, 2019, physicians and other Qualified Healthcare Providers (“QHCPs”) eligible to independently bill for E/M services can obtain standalone reimbursement for Interprofessional Internet Consultations according to the following parameters:
Billing Practitioner. Billing for interprofessional services is limited to those practitioners that can independently bill Medicare for E/M services. Though the descriptors for codes 99446-99449 and 99451 only include “assessment and management service provided by a consultative physician,” the text in the Rule includes consultative QHCPs, so long as the consulting QHCP is eligible to independently bill Medicare for E/M services. CPT Code 99452 applies to the treating/referring physician or QHCP, and the rest of the codes apply to the consultative physician or QHCP.
Consent. Verbal patient consent must be documented in the patient’s medical record for each consultation. The patient’s consent must include assurance that the patient is aware of applicable cost-sharing.
Cost Sharing. Providers must collect the requisite copayment from the patient for each service billed, as with all Medicare Part B services.
Benefit of the Patient. The consultation must be undertaken for the benefit of the patient. Because the patient is going to be responsible for cost-sharing, CMS is concerned about distinguishing these Interprofessional Internet Consultations from those undertaken for the edification of the practitioner, such as information shared as a professional courtesy or as continuing education.
For assistance with receiving reimbursement for Interprofessional Internet Consultations, please contact Nixon Law Group.
Interested in learning more about the 2019 Medicare Physician Fee Schedule? Check out some of our other posts by clicking the links below: