Evaluation and Management
- Can LCSWs use and bill for E/M codes such as 99212 or 99213?
Answer: The elements of E/M services (history, examination and MDM) are not within the scope of service for LCSWs and these services may not be billed by these providers at any level.
- Please explain the parameters for mental health services delivered via telehealth to a beneficiary who is at home.
Answer: In order to meet CMS guidelines, the mental health practitioner furnishing such services must have furnished both:
The provider must document any valid exception to these rules in the beneficiary’s record. Of note, the face-to-face visit requirement may be fulfilled by a clinician’s colleague of the same specialty and in the same group if the original provider is available. Please see FAQ #4 for further details on technology requirements for mental health practitioners providing services to beneficiaries at home.
- An in-person, non-telehealth service to the beneficiary with the 6-month period before the date of the telehealth service
- An in-person, non-telehealth service to the beneficiary within a 12-month period after the telehealth service, and within every 12-months thereafter while performing telehealth services
- Please define technology requirements are in place for providers who perform telehealth mental health services for beneficiaries at home.
Answer: Providers who perform such services must have access and capability to use interactive telecommunication technology that includes both audio and visual two-way, real-time communication capability. Exceptions to this rule are based on the beneficiary’s capability and agreement, as follows:
- The beneficiary may not be capable of audio/video communication OR the beneficiary may not consent to audio/video communication.
- In either of these circumstances, the provider must provide documentation in the patient’s medical record.
- Please describe modifiers applicable for telehealth mental health services provided to a beneficiary who is at home.
Answer: The following CMS modifiers apply in these instances:
- Modifier FQ: a telehealth service was furnished using real-time audio-only communication
- Modifier FR: a supervising practitioner was present throughout a real-time two-way audio/video telehealth service.
Note: Modifiers FQ and FR are required on these claims as of 4/1/2022.