CMS Updates Outpatient Therapy Code List for 2021

CMS
​​On December 31, 2020 the Centers for Medicare and Medicaid Services (CMS) posted MLN Matters Article (MM12126) which announced the annual update to the list of codes that describe Medicare Part B outpatient therapy services, effective January 1, 2021. The additions, changes, and deletions to the therapy code list reflect those made in the Calendar Year (CY) 2021 CPT and Level II HCPCS. The official instructions for Medicare Administrative Contractors (MACs) are described in CR 12126. You’ll find the therapy code listing reflecting the changes noted in the article here once they are posted. Make sure your billing staffs are aware of these updates.

Highlights:
Several existing and new codes introduced during the COVID-19 public health emergency (PHE) impacting SNF providers for use under physical therapy (PT), occupational therapy (OT), or speech-language pathology (SLP) plans of care were recently made permanent.  CMS discussed the policies implemented in this notification in CY 2021 Medicare Physician Fee Schedule (MPFS) rulemaking. CR 12126 updates the therapy code list and associated policies for CY 2021. CMS designated all these HCPCS/CPT codes as “sometimes therapy,” to permit physicians and certain Non-Physician Practitioners (NPPs), including nurse practitioners, physician assistants, and clinical nurse specialists, to render these services outside a therapy plan of care when appropriate.

Further, these HCPCS/CPT codes are considered communication technology-based (CTB) services and replace codes for similar services that CMS included in CR 11791. For the five codes below (2 HCPCS and 3 CPT codes), CY 2021 rulemaking made these codes permanent, meaning they are no longer restricted by the effectiveness timeline of the COVID-19 PHE. The HCPCS codes and long descriptors include:

  • HCPCS code G2250 - Remote assessment of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment. HCPCS code G2250 replaced HCPCS code G2010. 
  • ​HCPCS code G2251 - Brief communication technology-based service, e.g., virtual check-in, by a qualified health care professional who cannot report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available. HCPCS code G2251 replaced HCPCS code G2012.
The CPT Editorial Panel for CY 2020 created CPT codes 98970, 98971, and 98972. During MPFS rulemaking for CY 2021, CMS decided to use these codes in place of G2061, G2062, and G2063, since their descriptors were similar. The CPT codes and their long descriptors are: 
  • CPT 98970 - Qualified nonphysician health care professional online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes. CPT code 98970 replaced HCPCS code G2061
  • CPT 98971 - Qualified nonphysician health care professional online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 11-20 minutes. CPT code 98971 replaced HCPCS code G2062. 
  • CPT 98972 - Qualified nonphysician health care professional online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 21 or more minutes. CPT code 98972 replaced HCPCS code G2063.

CR 11971 added the CPT codes for telephone assessment as “sometimes therapy” codes effective for the duration of the PHE for COVID-19. As with the other CTB services noted above, therapists in private practice and therapists who work for institutional providers, including SNF, may furnish these services. The CPT codes and their long descriptors are: 
  • CPT 98966 - Telephone assessment and management service provided by a qualified nonphysician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion. 
  • CPT 98967 - Telephone assessment and management service provided by a qualified nonphysician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion. 
  • CPT 98968 - Telephone assessment and management service provided by a qualified nonphysician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 21-30 minutes of medical discussion.
CMS is removing the following HCPCS codes from the therapy code list, effective for dates of service on and after January 1, 2021: 
  • ​G2010 
  • ​​G2012 
  • G2061 
  • G2062 
  • G2063