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March 2019 Client Newsletter

New CPT code approved to pay by Medicare

Payment for non-face-to-face communication with patients relatively new. But with new 2019 code G2012, you've got a new option for virtual check-ins with Medicare patients.


The first place to learn about the code is the long code descriptor:

  • 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).

If that format is too dense, here are the bullet points for what's in the G2012 descriptor:

  •  The service is communication technology-based.
  • The provider can be a physician or other qualified health care professional who reports E/M services (that means the physician, PA or NP has to be the one to make the call. Cannot be an RN, LPN or MA.).
  • The patient must be an established patient (meaning seen within the past 3 years).
  • The communication cannot be related to an E/M service from within the previous seven (7) days.
  • The communication cannot lead to an E/M service within 24 hours (or soonest available).
  • The code represents 5 to 10 minutes of medical discussion.

MPFS Final Rule

The 2019 Medicare Physician Fee Schedule for southern NJ for G2012 $15.57.

Why is Medicare offering this new code and paying for it? In the MPFS 2019 final rule, CMS acknowledges changes in communication technology have changed patient/provider interactions and expectations. Code G2012 emerged to represent brief check-in services to evaluate whether a visit is needed.

The final rule provides these additional details for the code:

  • CMS plans to monitor use, watching for things like whether frequency limitations are needed. Commenters noted that in areas like behavioral health, frequency limitations could hinder medically necessary virtual check-ins, such as for suicide prevention.
  • The service must be medically reasonable and necessary to warrant payment. Medicare isn't requiring any service-specific documentation requirements, though. However, the medical record must document verbal consent from the patient for each billed service.
  • CMS is allowing both audio-only real-time telephone interactions and synchronous, two-way audio interaction with video or other data transmission.
    • Remember that the interaction must be between the patient and billing practitioner, not clinical staff.
  • Cost sharing applies, and the beneficiary co-payment is not waived.
  • The service is available only to established patients, defined as patients who have "received professional services 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, within the past 3 years."
  • The language in the code descriptor states, "nor leading to an E/M service or procedure within the next 24 hours." Consequently, Medicare will be watching for an uptick in appointments occurring 25 hours or so after the call. Do not game the system to get around the 24-hour limitation.
  • Since the time frame is specified as 5-10 minutes, be sure that your total services for all of your services on a given day are reasonable and do not exceed 12 hours? Or whatever is reasonable for your practice. If this is used excessively, you can expect to be audited. We suggest documenting your call start & stop time in the medical record & document the discuss the same as any F2F discussion.

Please call me if you have any questions.

If you want to begin using this code, let me know so we can add it to your charge master. We will also need to know how much you want to charge. $25?

2019 Client Newsletter Archive