Audiology Telehealth Updates: Medicare

Please note that telehealth guidelines and policies related to the COVID-19 pandemic are changing rapidly. Some information in this article may have changed since the last update on May 7, 2021. While we strive to keep all our content current, it is recommended the clinicians reference primary sources of information (e.g., government or payer guidance) whenever possible.

The need for telehealth options for audiologic care was already apparent prior to the COVID-19 pandemic. Increased usage of telehealth as a modality of service provision has been necessary to provide timely access to care. In May 2020, cochlear implant programming procedure codes were made approved for reimbursement when provided remotely.¹ Multiple organizations, including the American Academy of Audiology, have advocated for the addition of other covered services to those reimbursable through Medicare. On March 30, 2021, the Centers for Medicare and Medicaid Services (CMS) released a new list of procedures that will be covered when provided via telehealth. These additions have not changed the list of Medicare covered services,² but add certain covered services to be reimbursable through Medicare when provided via telehealth. The purpose of this review is to discuss relevant topics in telehealth coding and billing changes taking effect on March 30, 2021.

State Regulation

Practitioners providing services via telehealth should be familiar with the originating site’s state law and regulatory policy on the provision of telehealth services. Practitioners should be licensed in the originating site’s state when providing telehealth services. Efforts are currently underway to establish the Audiology and Speech-Language Pathology Interstate Compact (ASLP-IC)³ to reduce regulatory burden and increase uniformity of licensure, facilitating timely access to care across state lines.

Types of Telehealth Services

Telehealth services in health care span several mediums, including:

• Telephone calls (synchronous)
• Digital, real-time audio and video call (synchronous)
• Digital, store-and-forward audio and/or video call (asynchronous)

Technological Requirements

New Medicare expansions for audiology services require use of HIPAA-compliant,^4,5 real-time audio and video conferencing. Other mediums such as telephone and store-and-forward are not payable by Medicare when used for covered services provided via telehealth but may be covered by other payers under certain circumstances. Practitioners should reference payer-specific telehealth guidance to determine to which mediums telehealth coverage has been extended.

Telehealth Sites

There are two distinct sites in the provision of telehealth:

• Originating site—This is the site from which the patient is requesting services. The patient’s location may be notated on the claim form at their physical address.
• Distant site—This is the site from which the practitioner is providing services. The practitioner’s location is notated by Place of Service (POS) codes.

Place of Service (POS) Codes

• POS Code 11—Office is the primary POS code used for typical face-to-face procedures provided by audiologists. Current convention is to report Code 11 when providing telehealth services to assure similar rates to in-person services. Payers may also require a modifier to be addended to the procedure code (see next section, Modifiers).
• POS Code 02—Telehealth is a POS code used to indicate services were provided through a telecommunications system. We do not recommend reporting of the POS Code 02. Instead, Medicare asks practitioners to report the POS Code 11—Office and append the -95 (Telehealth) modifier to CPT codes representing the remote services performed. However, other payer specific policies may recommend the use of this POS code.

Telehealth Modifiers

Certain payers may require practitioners to append modifiers when reporting clinical services provided via telehealth.

• Modifier -95 This modifier indicates that services were provided synchronously (in real-time) over a HIPAA-compliant communication medium. It is commonly used by Medicare alongside POS Code 11 for reporting of clinical procedures performed via synchronous telehealth.
• Modifier -GT This modifier indicates that services were provided synchronously (in real-time) over a HIPAA-compliant communication medium. Medicare no longer uses this modifier to indicate telehealth services, but some payers may ask for reporting of this modifier in lieu of the Modifier -95.
• Modifier -GQ This telehealth modifier may be used by specific payers under certain circumstances. Required usage of this modifier has become rare in recent years as reporting conventions have evolved.

Codes Added to Covered Telehealth Services: Medicare

Table 1 presents a list of audiology services payable through Medicare when provided via telehealth. When reporting these codes to Medicare, the POS Code 11—Office should be used with the Modifier –95 to indicate provision via telehealth.

Table 1. List of Audiology Telehealth Services Payable Through Medicare

Code	Descriptor
92550	Tympanometry and reflex threshold
92552	Pure-tone audiometry air
92553	Pure-tone audiometry air and bone
92555	Speech audiometry threshold
92556	Speech audiometry threshold with speech recognition
92557	Comprehensive hearing test
92563	Tone decay hearing test
92565	Stenger test pure tone
92567	Tympanometry
92568	Acoustic reflex testing, threshold
92570	Acoustic immittance testing (tympanometry, acoustic reflex threshold, and acoustic reflex decay testing
92587	Evoked auditory test limited
92601	Diagnostic analysis of cochlear implant, patient <7y, initial programming
92602	Diagnostic analysis of cochlear implant, patient <7y, subsequent reprogramming
92603	Diagnostic analysis of cochlear implant, patient ≥7y, initial programming
92604	Diagnostic analysis of cochlear implant, patient ≥7y, subsequent reprogramming
92625	Tinnitus assessment (includes pitch, loudness matching, and masking)
92626	Evaluation of auditory function for CI candidacy or postoperative status of a surgically implanted device(s); first hour
92627	Evaluation of auditory function for CI candidacy or postoperative status of a surgically implanted device(s); each additional 15 minutes
Effective: March 30, 2021Status: Temporary Addition for the PHE for the COVID-19 Pandemic—Added March 30, 2021When reporting these codes to Medicare, the POS Code 11—Office should be used with the Modifier –95 to indicate provision via telehealth.

Telehealth Audits

Please make sure you comply with all requirements for the provision of telehealth services. The increased adoption of telehealth services means the Department of Health and Human Services (HHS) Office of Inspector General (OIG) has increased its review of telehealth services provided under the Medicare and Medicaid programs.

Self-Pay

When insurance does not provide coverage for certain services when provided via telehealth, practitioners are able to seek reimbursement directly from the patient.

Practitioners should:

• Establish a fee schedule for telehealth services offered and
• Use transparency in billing patients for services provided.

Additional Resources

COVID-19: Tracking of State Laws and Regulations for Telepractice and Licensure Policy.
American Speech-Language-Hearing Association. Accessed March 12, 2021.

Current State Laws and Reimbursement Policies.
Center for Connected Health Policy. Accessed March 12, 2021.

Medicare Telemedicine Health Care Provider Fact Sheet.
Centers for Medicare and Medicaid Services. Accessed March 12, 2021.

OIG Statement on Telehealth.
HHS-OIG Principal Deputy Inspector General Grimm on Telehealth. Access May 4, 2021.

Endnotes

1. Chakrabarty S, Jilla A, Miller E. Specialty Series: Telehealth. Audiology Today2020. p. 56-62.

2. Audiology Codes List, effective 01/01/2021. Centers for Medicare and Medicaid Services. Accessed March 12, 2021. https://www.cms.gov/Medicare/Billing/TherapyServices/Downloads/Audiology_Codes.pdf

3. Audiology and Speech-Language Pathology Interstate Compact (ASLP-IC). Accessed March 12, 2021. https://aslpcompact.com/about/

4. HIPAA and COVID-19. Department of Health and Human Services. Accessed March 12, 2021. https://www.hhs.gov/hipaa/for-professionals/special-topics/hipaa-covid19/index.html

5. HIPAA Administrative Simplification Regulation Text 45 CFR Parts 160, 162, and 164. Department of Health and Human Services. Accessed March 12, 2021. https://www.hhs.gov/wp-content/uploads/legacy/ocr/privacy/hipaa/administrative/combined/hipaa-simplification-201303.pdf?language=es