HHSC to End Telephone (Audio-only) Medical Services COVID-19 Guidance and Issue Temporary Guidance for Certain Audio-Only Services

Date: May 8, 2023

Attention: All Providers

Effective date: May 12, 2023

Call to action: Texas Children’s Health Plan (TCHP) would like to inform providers that effective May 11, 2023, Health and Human Services Commission (HHSC) will end the temporary flexibility that has been allowed for telephone (audio-only) medical (physician-delivered) E/M services. HHSC authorized providers to bill procedure codes 99201-99205 and 99211-99215 to receive reimbursement for telephone (audio-only) medical (physician-delivered) E/M services delivered from March 20, 2020, through May 11, 2023.

Billing information:

• Providers should continue to use modifier 95 to indicate remote delivery through May 11, 2023.
• Through the end of the PHE, telephonic E/M services must not be billed if it is determined that an in-person or telemedicine (audio-visual) office visit is needed within 24 hours or at the next available appointment. In those cases, the telephone service will be considered part of the subsequent office visit.
• If the telephone call follows an office visit performed and reported within the past seven calendar days for the same diagnosis, then the telephone services are considered part of the previous office visit and are not billed separately.
• Effective May 12, 2023, providers should begin using modifier 93 to indicate audio-only remote delivery of services.

Background information:

• In response to the COVID-19 federal public health emergency (PHE), the Texas Health and Human Services Commission (HHSC) authorized providers to bill procedure codes for telephone (audio-only) medical evaluation and management (E/M) services delivered from March 20, 2020, through May 11, 2023.
• In alignment with H.B. 4, HHSC issued interim guidance for providers titled “HB4: Interim Guidance for Non-Behavioral Health Audio-only Medical Office Visits” that will take effect May 12, 2023, to allow some audio-only services to continue beyond the PHE for the Fee For Service (FFS) program.
• This interim guidance authorizes Medicaid FFS providers to submit claims for reimbursement of the following non-BH services for established clients by synchronous telephone (audio-only) technology when appended with modifier 93. For BH services that may be delivered via synchronous telephone (audio-only) in Medicaid FFS, please click here for the TMPPM, Behavioral Health and Case Management Services Handbook and Children’s Services Handbook for additional information.

Note: These codes are currently and will continue to be allowable for synchronous audiovisual delivery as outlined in the TMPPM.

For non-BH services, procedure code 99211 may not be delivered via synchronous telephone (audio-only) technology but may be delivered via synchronous audiovisual technology when appended with modifier 95.

For all the services listed above, providers must follow the standard of care requirements outlined in their licensing regulations. The service should only be delivered via synchronous telephone (audio-only) technology if the provider determines it is clinically appropriate and the client receiving the services or the recipient’s legally authorized representative agrees.

Additional guidance from HHSC:

• Whenever possible, HHSC encourages face-to-face interaction, such as in-person visits or synchronous audio-visual technology, in place of telephone audio-only technology for telemedicine and telehealth services.
• The service should only be provided by audio-only delivery as medically necessary and in alignment with Section 111.007 of the Texas Occupations Code.

 Resource: Texas Medicaid Provider Procedures Manual, Telecommunication Services Handbook

If you have any questions, please email Provider Relations at: providerrelations@texaschildrens.org.

For access to all provider alerts,log into:
www.thecheckup.org or www.texaschildrenshealthplan.org/for-providers.