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LDH HPA 20-6: COVID New E-Consults

Date: 03/16/21

Recently released revision to HPA 20-6: Reponse to COVID, LDH issued guidance around E-Consults for COVID-19.

Effective for dates of service on or after March 15, 2021, Louisiana Medicaid will reimburse interprofessional assessment and management services that occur electronically through EHR, through audio/video platforms, or via telephone (e-consults).

A qualifying assessment and management service is one in which a member’s treating practitioner requests the opinion and/or treatment advice of a practitioner with a specific specialty or subspecialty different from the requesting practitioner, to assist the treating practitioner in the diagnosis and/or management of the member’s presenting issue. (See additional information below for CPT code 99451.)

Treating and remote/e-consultant practitioners include the following types: physicians, advanced practice registered nurses, physician assistants, psychologists, and other licensed mental health professionals.

All e-consults must be conducted through a secure internet exchange between the treating practitioner and the consultant*. The system used to complete the e-consult must, at a minimum, comply with the following requirements:

  • Be in compliance with current HIPPA and other applicable security and privacy requirements;
  • Enable transmission through electronic communication systems to a specialist who uses the information to evaluate the cases for the type of e-consults for which it is used; and
  • Be compatible with the primary care or treating provider’s electronic health records system.

*For the duration of the COVID-19 emergency, when a secure electronic exchange is not available, or the practitioners do not have a compatible electronic health record system, interprofessional assessment and management services may be rendered via audio/visual (telehealth) platforms or telephone. Practitioners must document the reason for using telehealth or telephonic communications. Documentation in the clinical records must substantiate the service.

The purpose of remote interprofessional assessment and management via e-consults, audio/visual platforms, or telephone is to replace a face-to-face evaluation and management (E/M) visits that would be performed by a practitioner with that specialty/subspecialty.

E-consult codes for interprofessional assessment and management are not reimbursable if there has been an E/M visit with the specialist/subspecialist during the time period of 14 days prior to or will be an E/M visit 14 days after the remote interprofessional assessment and management occurs (or at the next available appointment date with the specialist if that date is greater than 14 days) if:

  • The E/M visit was/is related to the original issue, and
  • The E/M visit is with the same specialist/subspecialist (or group) and was completed in addition to the interprofessional assessment and management.

In this circumstance, the e-consult codes shall not be billed for interprofessional assessment and management services when the specialist/subspecialist will bill for an E/M visit. In addition, e-consult codes shall not be billed for regular communication that is expected to occur between a physician and an APRN collaborating with, or a PA supervised by, the physician. Failure to adhere to this policy may result in recoupment.

All documentation for interprofessional assessment and management is to include the medical/behavioral health conclusions and any recommendations for treatment written by the specialist/subspecialist. All documentation for the interprofessional assessment and management must be retained in the member’s medical record. This applies to both the treating and specialty practitioners.

Relevant CPT procedure codes are:

99451: Interprofessional telephone/internet/electronic health record assessment and management service provided by a consultative physician, including a written report to the patient’s treating/requesting physician or other qualified healthcare professional; 5 minutes or more of medical consultative time (used by the specialist/subspecialist clinician).

Providers are encouraged to review the entire HPA20-6 for additional updates.