CMS Pub. 100-04, ch. 12, § 190.3.2

Initial Inpatient Defined

(Rev. 3817; Issued; 07-28-17 Effective; 01-01-18 Implementation: 01-02-18)

Emergency department or initial inpatient telehealth consultations are furnished to

beneficiaries in hospitals or SNFs via telehealth at the request of the physician of record, the

attending physician, or another appropriate source. The physician or practitioner who

furnishes the emergency department or initial inpatient consultation via telehealth cannot be

the physician of record or the attending physician, and the emergency department or initial

inpatient telehealth consultation would be distinct from the care provided by the physician of

record or the attending physician. Counseling and coordination of care with other providers

or agencies is included as well, consistent with the nature of the problem(s) and the patient’s

needs. Emergency department or initial inpatient telehealth consultations are subject to the

criteria for emergency department or initial inpatient telehealth consultation services, as

described in section 190.3.1 of this chapter.

Payment for emergency department or initial inpatient telehealth consultations includes all

consultation related services furnished before, during, and after communicating with the

patient via telehealth. Pre-service activities would include, but would not be limited to,

reviewing patient data (for example, diagnostic and imaging studies, interim labwork) and

communicating with other professionals or family members. Intra-service activities must

include the three key elements described below for each procedure code. Post-service

activities would include, but would not be limited to, completing medical records or other

documentation and communicating results of the consultation and further care plans to other

health care professionals. No additional E/M service could be billed for work related to an

emergency department or initial inpatient telehealth consultation.

Emergency department or initial inpatient telehealth consultations could be provided at

various levels of complexity:

• Practitioners taking a problem focused history, conducting a problem focused

examination, and engaging in medical decision making that is straightforward,

would bill HCPCS code G0425 (Telehealth consultation, emergency department

or initial inpatient, typically 30 minutes communicating with the patient via

telehealth).

• Practitioners taking a detailed history, conducting a detailed examination, and

engaging in medical decision making that is of moderate complexity, would bill

HCPCS code G0426 (Telehealth consultation, emergency department or initial

inpatient, typically 50 minutes communicating with the patient via telehealth).

• Practitioners taking a comprehensive history, conducting a comprehensive

examination, and engaging in medical decision making that is of high complexity,

would bill HCPCS code G0427 (Telehealth consultation, emergency department

or initial inpatient, typically 70 minutes or more communicating with the patient

via telehealth).

Although emergency department or initial inpatient telehealth consultations are specific to

telehealth, these services must be billed with POS 02 to identify the telehealth technology

used to provide the service.