Before January 1, 2023, Home Health Agencies (HHA) lacked telehealth codes that involved collecting data at the patient level when submitting home health (HH) claims within 30-day periods. Despite requiring services delivered via telecommunications systems to become part of a patient’s plan of care, the Centers for Medicare & Medicaid Services (CMS) could not regularly determine whether those services were provided when processing HH claims for billing. In response, CMS implemented three additional telehealth codes, which took effect on January 1, 2023.
These telehealth codes will encourage HHAs to voluntarily report the telecommunications technology provided to patients during care periods, to Medicare Administrative Contractors (MACs) when billing on services rendered. However, starting July 1, 2023, these telehealth codes will become mandatory for HH payment claims submitted within care periods on or after July 2023. To help prepare caregivers, patients, and providers, we’ve provided this blog highlighting key details regarding each G-code.
What are “G-Codes”?
CMS requires HH claims for telemedicine interactions conducted via telecommunications technology to be part of a patient’s known plan of care for coverage. These payments are submitted using the Healthcare Common Procedure Coding System (HCPCS), a standardized code system necessary for medical providers to submit healthcare claims. HCPCS has two categories, I and II. G-codes fall under the latter, “what the provider used.” Specifically, G codes are revenue codes assigned by CMS to identify professional healthcare procedures and services for billing.
As defined by CMS, these claims can extend to audio or video-based therapy sessions within 30-day periods and the remote monitoring of physiologic data sent to home health agencies (HHA). These new HCPCS codes are not considered a home visit for the purposes of:
- Patient eligibility or payment, per section 1895(e)(1)(A) and (B) of the Social Security Act
- Outlier unit amounts sent to the HH Pricer
- Calculating Low Utilization Payment Adjustment (LUPA) add-on payments
- Ensuring covered skilled visit requirements are met
- Review of claims with unusually high numbers of covered visits
- Total visits counts and validation of the total visits counts shown in value codes 62 and 63
How These Codes Work
Any telehealth services provided to patients should be part of that patient’s plan of care. Following January 1st, 2023, providers may voluntarily report the use of telecommunications technology in HH claims for services rendered. On July 1st, 2023, all HHA must report to the CMS when submitting telehealth claims. These reports will be used for data collection and categorized by one of the three new telecommunications G-codes, G0320, G0321, and G0322, consistent with an individual’s plan of care on HH cost reports.
HHAs must document each telehealth interaction to reveal how much of an impact telecommunications technology has in achieving the goals outlined in plans of care. Each plan must clearly define which technology was responsible for executing a patient’s specific needs within a comprehensive assessment.
Telehealth’s New G-Codes
Within the HH industry, the use of telecommunications technology for reporting before the start of 2023 had been limited to cost data on a broad category of telecommunications services as a part of an HHA’s administrative cost reports. These three G-codes were enacted to better understand and improve patients’ plans of care through data collected on the patient level.
G0320
Following the implementation of telehealth code G0320, HHAs offering synchronous telemedicine support are advised to administer said services through real-time two-way audio and video telecommunications. After these telehealth interactions, providers must report each HH claim using a separate dated line paired with the correct revenue code classified under the medical discipline of each service. This correction will help identify when these two-way services were granted for accurate billing purposes.
G0321
Per telehealth code G0321, providers who offer synchronous audio-only telemedicine care are suggested to house them under telecommunications systems. These resources can vary from telephone calls to other real-time interactive services. After each telehealth visit, you must report every interaction with a separate dated line based on the relevant revenue code connected to each medical discipline administered for those services.
G0322
Under the telehealth G0322 code, all physiologic data submitted digitally by beneficiaries or caregivers to HHAs will be impacted for remote patient monitoring. This patient-specific data is gathered by remotely tracking chronic conditions that can adversely affect one’s health, such as high blood pressure, glucose levels, sleep apnea, heart conditions, or diabetes. When reporting these claims as single line items, providers must list the start date and the total number of days monitored in each period to account for every field unit measured during that time.
How New Telehealth Codes Affect Home Health Reporting
By implementing these telehealth codes, CMS can incorporate benefits unique to each patient’s plan of care using their specific telecommunications data. These opportunities will include analyzing data points from multiple patients receiving telemedicine care. This way, CMS can gain a deeper understanding of which patients benefited the most from those services while addressing barriers to entry for other groups. Additional claims submission requirements will also be mandatory when reporting on a G-code. For instance, HHAs can only submit codes on Type of Bill 032x when paired with revenue codes 042x, 043x, 044x, 055x, 056x, and 057x. If claims containing HCPCS codes G0320, G0321, and G0322 are submitted without another line item with the same revenue code and a G-code other than G0320, G0321, and G0322, they will be denied.
Ex: A claim with a line reporting revenue code 0551 and G0320 must also have a revenue code 055x line containing HCPCS G0299, G0300, G0162, G0493, G0494, G0495, or G0496.
Conclusion
The first COVID–19 Public Health Emergency (PHE) interim final rule in 2019 made providing and receiving services via telecommunications technology more accessible. Since then, telemedicine has steadily increased and has become a viable option for patients to receive necessary care and treatment. As such, these new telehealth codes will only become more relevant as we progress due to the rise of telehealth services. Ultimately, this will require the CMS to continue reviewing HH claims to determine which telecommunications technologies aided patients and how telemedicine can be adapted to fit their plan of care.
For further information regarding changes coming to Home Health, please reach out to KanTime, and our industry experts would be delighted to assist you with a consultation.
