To begin, both telehealth and virtual communication services (VCS) use technology for communication, but according to the Centers for Medicare & Medicaid Services (CMS), these are separate and distinct services.

“Telehealth services are considered a substitute for an in-person visit, and are therefore paid at the same rate as it would have been had it been furnished in person. With some exceptions, telehealth services require the use of interactive audio and digital telecommunication systems that permit real-time communication between the practitioner at the distant site and the beneficiary at the originating site.”

The Center for Connected Health Policy defines Telehealth as “a collection of means or methods for enhancing health care, public health and health education delivery and support using telecommunications technologies.” The use of these telecommunication technologies and services are not considered a substitute for a visit according to CMS but are meant to be brief communications between the patient and the Federally Qualified Health Center (FQHC) provider to determine if an actual visit is necessary. If the communication between the FQHC provider and the patient results in a billable visit, then the normal billing would occur. The virtual communication G-code would only be separately payable if the communications between the FQHC provider does not result from or lead to an FQHC billable visit. Furthermore, “the payment rate for communication technology-based services are valued based on the shorter duration of time and the efficiencies associated with the use of communication technology.”

More about “virtual communication services” from CMS:

In the 2019 Physician Fee Schedule (PFS) Final Rule, CMS finalized a policy that, effective January 1, 2019, RHCs and FQHCs can receive payment for virtual communication services when at least 5 minutes of communication technology-based or remote evaluation services are furnished by an RHC or FQHC practitioner to a patient who has had an RHC or FQHC billable visit within the previous year, and both of the following requirements are met: (1) The medical discussion or remote evaluation is for a condition not related to anRHC or FQHC service provided within the previous 7 days, and (2) The medical discussion or remote evaluation does not lead to an RHC or FQHCvisit within the next 24 hours or at the soonest available appointment.

Billing Codes

  • Brief Communication Technology-based Service, e.g. Virtual Check-in Includes check-in services used to evaluate whether or
    not an office visit or other service is necessary (FQHCs may bill G0071). The Medicare payment for these services is $13.69 (average of HCPCS codes G2012 and G2010) 
  • Remote Evaluation of Pre-Recorded Patient Information – New code to describe the remote professional evaluation of patient-transmitted information conducted via prerecorded “store and forward” video or image technology (FQHCs may bill G0071). The Medicare payment for these services is $13.69 (average of HCPCS codes G2012 and G2010) 

Important Points to Keep in Mind:

  • The new code to bill for VCS (live video or store-and-forward) is G0071.
  • There must be at least 5 minutes of communication.
  • The patient must have been seen by the FQHC in the past year.
  • The service is provided by an FQHC practitioner.
  • FQHCs will NOT receive their PPS rates.
  • Coinsurance would apply to FQHC claims.
  • Face-to-face requirement is waived.
  • These are not to be considered substitutions for an in-person visit.
  • No frequency limitation is implemented at this time

If you have additional questions about telehealth or virtual communication services (G0071), don’t hesitate to reach out and we will do everything in our power to assist you.