CTP Documentation and Billing 5 — Questions and Answers
Question 1: A rural health clinic (RHC) patient receives a telehealth visit from a specialist at a distant site. Which facility is eligible to bill for an originating site fee?
- The specialist's distant site office
- The rural health clinic where the patient is physically present (Correct answer)
- The patient's home if internet-connected
- Neither site; originating site fees were eliminated in 2023
Correct answer: The rural health clinic where the patient is physically present
Under Medicare, an approved originating site facility like an RHC may bill HCPCS code Q3014 for the originating site facility fee when hosting the patient.
Question 2: A telehealth provider documents 'patient connected via video, audio quality adequate, patient identity verified.' Why is this type of statement important?
- It satisfies HIPAA encryption documentation requirements
- It demonstrates the service met synchronous telehealth standards required for billing with Modifier 95 or GT (Correct answer)
- It replaces the need for a signed consent form
- It is required by DEA for telehealth prescribing of all medications
Correct answer: It demonstrates the service met synchronous telehealth standards required for billing with Modifier 95 or GT
Documenting that a real-time audio-video connection was established and functional supports the use of synchronous telehealth modifiers and defends the claim in audit.
Question 3: Under the 2024 CMS rules, which provider type is NOT on the list of eligible distant site providers for Medicare telehealth?
- Nurse practitioners (NPs)
- Clinical psychologists
- Dentists providing dental care (Correct answer)
- Clinical social workers
Correct answer: Dentists providing dental care
Medicare telehealth coverage does not extend to dental services; dentists providing dental care are excluded from the Medicare distant site provider list.
Question 4: Which of the following best describes 'upcoding' in the context of telehealth billing?
- Using Modifier 95 to indicate a video visit was performed
- Billing a higher-level E/M code than the documentation supports (Correct answer)
- Assigning the correct diagnosis code to a telehealth claim
- Applying POS 10 for a home-based telehealth encounter
Correct answer: Billing a higher-level E/M code than the documentation supports
Upcoding is billing for a higher service level than actually documented or provided, which is considered fraud and can result in significant penalties.
Question 5: A practice discovers that 50 telehealth claims over the past year were incorrectly billed with Modifier 95 when the visits were actually audio-only. What is the appropriate corrective action?
- Do nothing since the visits were still rendered
- Conduct a voluntary repayment to the payer and correct future claims (Correct answer)
- Bill the patients for any recovered amounts
- Submit new claims using the same codes and modifiers
Correct answer: Conduct a voluntary repayment to the payer and correct future claims
When billing errors are identified, providers should conduct a voluntary disclosure and repayment to avoid False Claims Act exposure, and correct processes going forward.
Question 6: For a telehealth visit to count toward the 2024 E/M time-based billing threshold, which of the following must be true?
- The provider must document total face-to-face time only
- The provider must document total time on the date of the encounter, including pre- and post-visit work (Correct answer)
- The visit must be at least 60 minutes to qualify for time-based billing
- Time-based billing is not permitted for telehealth services
Correct answer: The provider must document total time on the date of the encounter, including pre- and post-visit work
Per 2021 AMA E/M guideline updates, total time on the date of the encounter — including pre-visit prep and post-visit documentation — counts toward the E/M time threshold for both in-person and telehealth visits.
Question 7: Which of the following is a common compliance risk specific to telehealth billing that practices should address in their compliance programs?
- Patients using outdated browsers for video visits
- Billing telehealth services for patients in states where the provider is not licensed (Correct answer)
- Using HIPAA-compliant platforms that charge a monthly fee
- Documenting the patient's preferred pharmacy in the note
Correct answer: Billing telehealth services for patients in states where the provider is not licensed
Providing and billing telehealth services in states where the provider lacks licensure is an unlicensed practice of medicine and a significant compliance and legal risk.
CTP Documentation and Billing 5
A rural health clinic (RHC) patient receives a telehealth visit from a specialist at a distant site.
Which facility is eligible to bill for an originating site fee?