Avoid These Five Compliance Traps When Billing Virtual Services

During COVID-19, much of the business world went virtual, and healthcare is no exception. In a matter of days, providers nationwide began to embrace telehealth, online digital evaluation and management (E/M) services, and telephone visits. However, these services are new territory for many practices, and thus there are inherent compliance risks that practice managers must address, says Toni Elhoms , CCS, CPC, chief executive officer of Alpha Coding Experts, LLC in Orlando, Florida, and shares five compliance traps to avoid:

1. Not knowing what codes to report

Following are appropriate codes to consider:

• Telephone services: Report CPT codes 99441-99443, 98966-98969, or G2012.
• Online digital E/M services: Report CPT codes 99421-99423, 98970-98972, or G2061-G2063.
• Telehealth for Medicare: Medicare wants the place of service code (POS) to match the CPT code. So, a home services code (999341-99350) would have POS 12 Note that some of these codes specify physician vs. nonphysician healthcare professional. Others are Medicare specific.

2. Assuming commercial payers follow Medicare 

Contact each commercial payer to identify whether they cover some or all virtual services. For telehealth, be sure to ask whether each payer requires audio visual, or whether it permits audio only. Most commercial payers have comprehensive policies posted on their websites.

3. Relaxing telehealth documentation 

Just because it’s a virtual visit doesn’t mean physicians can go easy on their documentation. For example, when billing telehealth, physicians must continue to document relevant details to demonstrate they met all of the code requirements. During the current public health emergency (PHE), physicians can bill 99201-99215 rendered via telehealth based on time or medical decision making (MDM). As of January 1, 2021, physicians will officially use time or MDM, making it paramount to ensure documentation reflects both of these elements.

The same is true for telephone visits. Physicians need to document specifically what they discussed with the patient as well as the outcome of the conversation. For example, did they prescribe any medications? Refer the patient to a specialist? For online digital E/M services, document what specific data was reviewed as well as the care plan and subsequent communication of that plan to the patient or their caregiver through online, telephone, email, or other digitally-supported communication.

4. Billing telephone visits or online digital E/M services lasting fewer than five minutes. 

These services require a minimum of five minutes of medical discussion with the patient or making a clinical decision that would have otherwise occurred during an in-person office visit. If the conversation is fewer than five minutes, it’s not billable at all.

5. Not understanding pre- and post-visit requirements. 

Don’t report telephone visits when the service ends with a decision to see the patient in 24 hours or the next available appointment. Also don’t report telephone services when they’re related to an E/M service performed within the previous seven days or within the postoperative period of a previously completed procedure. Both of these instructions are also true for online digital E/M services.


When billed correctly—and with supporting documentation—virtual services not only improve patient access but they also drive revenue. A 21-30-minute phone call with a Medicare patient, for example, yields approximately $41. Likewise, an online digital E/M service lasting 21 or more minutes for an established patient with Medicare yields approximately $50. However, as with all codes, it all comes down to documentation. If it’s not documented, it didn’t happen. If your practice already bills these codes—or plans to do so in the near future—ensure documentation is up to par to avoid payer scrutiny.

For more information on billing best practices, plan to attend out free live webinar on Wednesday, October 21 at 10 a.m. Pacific time. Kareo's Billing Subject Matter Expert, Terri Joy, MBA, CPC, CGSC, COC, CPC-1, will be sharing the 10 medical billing KPIs medical billers need to know to prevent their practice or client's practice from losing money. Click here to save your seat. 

About the Author

Lisa A. Eramo, BA, MA is a freelance writer specializing in health information management, medical coding, and regulatory topics. She began her healthcare career as a...

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