CTP Documentation and Billing 4 — Questions and Answers
Question 1: What is the primary purpose of documenting the 'chief complaint' in a telehealth SOAP note?
- To satisfy HIPAA minimum necessary standards
- To establish medical necessity for the level of service billed (Correct answer)
- To comply with state telehealth prescribing laws
- To determine the patient's originating site fee eligibility
Correct answer: To establish medical necessity for the level of service billed
The chief complaint is fundamental to establishing medical necessity, which payers require to justify the billed E/M level for any service including telehealth.
Question 2: A telehealth claim is submitted with the wrong Place of Service code. The payer denies it. What is the FIRST step the biller should take?
- Write off the claim as uncollectable
- Correct the POS code and resubmit the claim within the payer's timely filing window (Correct answer)
- File a formal grievance with the state insurance commissioner
- Bill the patient directly for the full amount
Correct answer: Correct the POS code and resubmit the claim within the payer's timely filing window
Administrative denials for coding errors like wrong POS codes are typically correctable by resubmitting with the accurate code, provided it is done within the payer's timely filing deadline.
Question 3: Under CMS guidelines, which of the following patient locations was traditionally NOT eligible as an originating site for Medicare telehealth before COVID-19 waivers?
- Federally Qualified Health Centers (FQHCs)
- Rural Health Clinics (RHCs)
- Hospital outpatient departments
- The patient's own home (for non-end-stage renal disease patients) (Correct answer)
Correct answer: The patient's own home (for non-end-stage renal disease patients)
Prior to COVID-19 PHE waivers, the patient's home was generally not an approved Medicare originating site; patients had to travel to an approved facility in a rural area.
Question 4: Which documentation element helps differentiate a new patient telehealth visit (99202–99205) from an established patient visit (99212–99215) when audited?
- The date of birth recorded in the header
- Evidence that no professional service was provided by the provider or group in the past 3 years (Correct answer)
- The patient's insurance type
- The length of the video session in minutes
Correct answer: Evidence that no professional service was provided by the provider or group in the past 3 years
A new patient is defined as one who has not received a professional service from the provider or any other provider of the same specialty in the same group within the past 3 years.
Question 5: A provider bills a 30-minute psychiatric telehealth session. Which CPT code family is most appropriate?
- 99202–99215 (E/M office visits)
- 90832–90838 (psychotherapy add-on codes) (Correct answer)
- 90791–90792 (psychiatric diagnostic evaluations)
- 99441–99443 (telephone E/M)
Correct answer: 90832–90838 (psychotherapy add-on codes)
CPT 90832 (30 minutes) is part of the psychotherapy codes used for interactive complexity sessions, appropriate for a 30-minute psychiatric therapy telehealth visit.
Question 6: Which federal agency oversees and sets Medicare telehealth billing policies, including eligible services and provider types?
- Office of Civil Rights (OCR)
- Centers for Medicare & Medicaid Services (CMS) (Correct answer)
- Department of Health and Human Services (HHS)
- Federal Trade Commission (FTC)
Correct answer: Centers for Medicare & Medicaid Services (CMS)
CMS is the federal agency responsible for administering Medicare and issuing coverage, coding, and billing rules for telehealth services under the Medicare program.
Question 7: What does the term 'distant site' refer to in the context of Medicare telehealth billing?
- The location of the patient during the telehealth visit
- The location of the rendering provider during the telehealth visit (Correct answer)
- The location of the billing department
- The server location of the telehealth platform
Correct answer: The location of the rendering provider during the telehealth visit
The distant site is the location of the healthcare provider delivering the telehealth service, as defined by CMS for Medicare telehealth billing.
What is the primary purpose of documenting the 'chief complaint' in a telehealth SOAP note?