Q&A: Medicare screening changes and new E/M service codes

Q1:  Medicare notified our group that effective 1/1/2020 they would no longer going to pay for the G0444 (depression screening) and G0443 (alcohol screening) to be performed together at the same visit. They will still pay for the two screenings but only if they are done at separate visits. Why would Medicare do this when these are clearly measures they want providers to perform?

A1:  Each Medicare contractor can make certain coverage modifications. We can’t say specifically what caused them to do that. And they don't always explain themselves. There do not appear to be  NCDs, LCDs and or Contractor articles on this.

That said, there have been comments made about these codes in general that might apply. See if these make sense. 

"In recent years, the CMS has expanded Medicare coverage of preventive services. These services (and their corresponding Medicare billing codes) include:

• Annual alcohol misuse screening, 15 minutes (G0442)

• Brief face-to-face behavioral counseling for alcohol misuse, 15 minutes (G0443)

• Annual depression screening, 15 minutes (G0444)
   

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Unfortunately, Medicare contractors have determined that insufficient documentation is causing many improper payments for these services. “Insufficient documentation” in this context means that something was missing from the medical records, such as:

• No record of the amount of time spent providing a timed service

• No record of the billed service itself

• No physician’s signature on the medical record

To avoid these potential problems, CMS advises physicians to:

• Record start and stop times, or the total time spent, when providing a timed service

• Sign entries in medical records at the time of service
   

It could easily be one of these concerns, perhaps in relation to audited claims, or something else entirely.

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Q2: There are new digital E/M services when patients email us through the patient portal,  CPT codes 99421, 99422 and 99423. Do you know if patients will incur cost-sharing if we use these codes? 

A: Yes, traditional Medicare patients would have a minor co-pay. In the area of $3 for the lowest code depending where you are located. We do get a lot of questions from providers that are ok with taking the payment for their work if it comes only from a third-party payer, but that don't want to deal with patient complaints about co-pays. 

Forward looking practices are doing this, but it requires some organization. Some larger groups have not made these codes available to their providers in part because there is some potential for abuse with these. 

Since these are timed codes, there needs to be some documentation of the time spent. And there needs to be a way to make sure a record of these interactions is saved. When deploying a ‘service line’ of this sort make sure that your providers have some guidance, guardrails and mindful monitoring.

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And to that end-make sure the patient understands what is involved as well. Before you'd initiate these types of services with your patients, you'd be well off to give them a heads up about any co-pays, which of course are payer specific. And probably a sales pitch on what a great time and energy saver it is versus an office visit. Remind them that this is MD time, that's what's being billed and paid for here.

There are three codes for providers that cannot bill directly–codes 98970-98972. Look into those as well if they fit your group.