What is Virtual Communication (G0071)?
Shannon DeConda, CPC, CEMC, CEMA, CPMA, CRTT
Partner of DoctorsManagement and President of NAMAS
Beginning January 1st, 2019 all of our RHC and FQHC organizations have a new CPT code to consider implementing for their Medicare populous (check per Advantage Plan Administration for coverage). In its current form, this code is not reportable by organizations not meeting the RHC/FQHC designation.
The code is G0071 and is termed as a Virtual Communication. As an auditor, one may ask what should we be on the lookout for when reviewing the use of this code? Let’s discuss the particulars of the code and then we will provide a checklist at the end to create ease in auditing these services.
First, let’s start by distinguishing the specific CMS wording. This visit descriptor is Virtual Communication and is not indicated as a telehealth service. The difference is that telehealth services are provided in lieu of an office visit. In other words, they take the place of the need for any additional encounter with the provider of record. The new G0071 code is a communication tool. CMS indicates they have created this code to allow a practitioner and patient remote interaction to decide if a visit is reasonable and medically indicated based on the patient’s current complaint and/or concern. There is no required software or portal interaction to provide this service. CMS indicates that this could be done via phone, portal or video experience. Should the provider’s opinion require a picture- the patient could send this to the provider as well. Creation of this service as a billable code (national average reimbursement is $13.00) should be seen as a positive, as this is a service that providers of all specialties and places provide nearly every day but are not reimbursed for.
As this often happens, a good new code is met with the ‘but’…
The ‘but’ with this code is, if the virtual communication leads to an office visit, the G0071 is not a reimbursable event; actually, this does make sense. CMS has a longstanding guidance that any service provided to a patient between encounters is considered “bundled” into the following encounter. Therefore, if the communication leads to an encounter (face-to-face) within 24 hours, then do not report G0071. There is one other rule that follows this same “bundled” thought process and that is, if the communication is regarding a condition that was addressed during an encounter within the past 7 days, the G0071 would again not be reportable.
While most communication in a practice is between ancillary staff and the patient, this code was not created to report this interaction. G0071 may only be reported to represent work performed requiring the skill set of a physician or other qualified healthcare provider (ex: NP, PA, CNS), however, there is no current frequency limitation on this code. Therefore, it may be reported per interaction. Additionally, this service is reimbursed only when the patient initiates this interaction. G0071 is a time based code and requires a minimum of 5 minute virtual communication to be a reported service.
As with some of the newer CMS approved services, you must obtain patient consent prior to providing the virtual communication. It’s a new year and most practices begin the year with updated patient demographics. While you’re updating this information, offer the patient a flyer on what a virtual communication encounter is and have them sign that they understand these encounters. Prior to scheduling the provider/beneficiary virtual communication, remind the patient that this is a billable encounter to CMS. In addition, your patient will be responsible for coinsurance for this service, and it is subject to their deductible.
The following is an audit checklist when reviewing the G0071. Keep in mind, even though this service is a non-face-to-face encounter, it still has the basic requirements of documentation indicating the reasonableness and medical necessity of the encounter.
The Audit Checklist is as follows:
- Patient consent must be obtained
- Service must be provided by a MD, DO or NPP, and initiated by the patient
- The communication may not be a result of a visit within the past 7 days
- If the communication leads to a face-to-face visit, then the code is not reported
- The documentation must include the following:
- Problem/Condition for the communication
- Details of the interaction
- Action plan as a result of the communication
- Total time of event (if less than 5 minutes the service is not reportable)
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