In last week’s Monday Minute, we discussed the ICD-10 coding changes that took place in the PDGM model that will begin on January 1, 2023. Today, we are going in more detail on the new G-codes that have been added for telehealth data collection, as well as a discussion regarding non-routine supplies.   

Telehealth G-code Definitions 

The below image shares content from the final rule that shows the three G-code definitions that have been added for telehealth in home health. The first G-code is going to identify when home health services are furnished using two-way audio/video so the patient and clinician can see and hear one another. The second telehealth code is specific to audio only, or phone calls with the patient, and lastly, remote patient monitoring.  

Figure 1: Three New G-Codes

Figure 2: G-Code Definitions

When the final rule was released, the G-codes had not yet been produced. When we got to the Change Request 12805that was issued just a couple of weeks ago, that Change Request  produced the three G-codes above. G0320, G0321, and G0322. G0320 is specific to real-time two-way audio/video. The G0321 code is specific to audio only, and G0322 is remote patient monitoring. The Change Request reiterates that any telehealth services provided to a patient should be part of that patient’s care plan. There should be defined interventions that will take place during these telehealth visits and how those visits are going to help the patient and the agency meet the goals that have been set for the patient. It is not a situation where your clinicians can wake up one day and say, “I’m not feeling great today, so I’m just going to do telehealth visits.” That is not acceptable and has never been. To be appropriately providing telehealth services, they must be a part of the patient’s care plan and defined interventions.These codes will be utilized on your claims for data collection purposes only beginning January 1, 2023. The data collection will begin voluntarily in January, but will be required effective July 1, 2023.  

Reporting Non-Routine Supplies on Claims

When it is said that these new G Codes are going to be effective or required in July, it is similar to the non-routine supply situation that we have been dealing with since the beginning of the Perspective Payment System back in the year 2000. It has always been required that non-routine supplies be reported on home health claims if those non-routine supplies were provided by the agency, however only about 10% of home health claims typically have a non-routine supply reported on the claim.

You might argue that most of your claims should have non-routine supplies on them, at least greater than 10%, but agencies have continued to not bill non-routine supplies, and because of that, we are not currently receiving additional reimbursement for non-routine supplies in our home health rates. They have a few cents built into the base rate for supplies and that is the result of supplies not being reported on the claim, which means it cannot be reported in the medical supply cost center on the cost report. If it is not on the claim and it is not on the cost report, it does not exist. CMS should not be responsible for paying us for supplies that we have not even documented that we provided to the patient. 

Why Report Telehealth Services? 

This telehealth situation makes us believe that we are going to head down a remarkably similar road with telehealth data collection in that we are not going to get reimbursed for it in 2023, so why report it? Why force ourselves to keep up with this and make sure that it hits the claim? The only reason you would do that is two things: first of all, it’s required. Second, if we don’t give them the information of the telehealth services that we are providing, we are never going to get reimbursement for it. We can’t blame CMS for that. If we are not using it, that is fine, and that reality is the case for many agencies. However, if we are using telehealth, it must be reported in hopes that eventually, seeing the volume of telehealth that home health agencies are now utilizing, it will begin to provide reimbursement for that service.  

Reporting on your claims any telehealth, using the three G-codes discussed, and all non-routine supplies, using the appropriate codes that have been in place for over 20 years, is extremely important. It is encouraged that you meet with your billing staff, and with your EMR systems, if necessary, to ensure that as of January 1, you have processes in place to perform any telehealth services that you deem necessary and begin reporting. Lastly, if you are not doing so already, all non-routine supplies that are being provided to your patients should also be reported on claims. 

If you have any questions related to billing, please contact us. Our team is here to help you succeed.