Telehealth update: Make sure to lock in medical necessity before billing phone E/Ms

Why This Topic Matters

Telehealth billing rules can change quickly, and this article highlights areas where practices may face denials, recoupments, or audit exposure if phone-based services are billed without sufficient medical necessity or proper documentation. It is relevant for organizations trying to align telehealth workflows with Medicare and CPT expectations during the PHE.

Article Sections

1. Temporary Medicare coverage and compliance cautions

   Introduces the temporary Medicare context for telephone-based evaluation and management services and the overall caution about billing them as telehealth. The section frames the article’s focus on compliance and documentation concerns.

2. Medical necessity and test-result follow-up scenarios

   Discusses general scenarios involving follow-up communication about diagnostic testing and the importance of medical necessity. It addresses how practices think about whether a call would have otherwise required an office return.

3. Routine results, portal communication, and audit concerns

   Reviews concerns about routine result notification and similar courtesy calls, along with payer scrutiny of telehealth billing patterns. It also notes the HHS OIG’s interest in telehealth billing during the pandemic.

4. Other CPT requirements for telephone E/M reporting

   Summarizes additional coding prerequisites discussed in the article, including timing considerations around recent patient encounters and potential follow-up care. This section reinforces the need to verify all reporting requirements before billing.