CMS Pub. 100-04, ch. 12, § 190.3.3

Follow-up inpatient telehealth consultations are furnished to beneficiaries in hospitals or

SNFs via telehealth to follow up on an initial consultation, or subsequent consultative visits

requested by the attending physician. The initial inpatient consultation may have been

provided in-person or via telehealth.

Follow-up inpatient telehealth consultations include monitoring progress, recommending

management modifications, or advising on a new plan of care in response to changes in the

patient’s status or no changes on the consulted health issue. 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.

The physician or practitioner who furnishes the inpatient follow-up consultation via

telehealth cannot be the physician of record or the attending physician, and the follow-up

inpatient consultation would be distinct from the follow-up care provided by the physician of

record or the attending physician. If a physician consultant has initiated treatment at an initial

consultation and participates thereafter in the patient’s ongoing care management, such care

would not be included in the definition of a follow-up inpatient consultation. Follow-up

inpatient telehealth consultations are subject to the criteria for inpatient telehealth

consultation services, as described in section 190.3.1 of this chapter.

Payment for follow-up 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 at least two of 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 evaluation and management service could be billed for work

related to a follow-up inpatient telehealth consultation.

Follow-up inpatient telehealth consultations could be provided at various levels of

complexity:

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

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

low complexity, would bill a limited service, using HCPCS code G0406 (Follow-up

inpatient telehealth consultation, limited, physicians typically spend 15 minutes

communicating with the patient via telehealth).

• Practitioners taking an expanded focused interval history, conducting an expanded

problem focused examination, and engaging in medical decision making that is of

moderate complexity, would bill an intermediate service using HCPCS code

G0407(Follow-up inpatient telehealth consultation, intermediate, physicians typically

spend 25 minutes communicating with the patient via telehealth).

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

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

complex service, using HCPCS code G0408 (Follow-up inpatient telehealth

consultation, complex, physicians typically spend 35 minutes or more communicating

with the patient via telehealth).

Although follow-up 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.