Prior to the pandemic, Medicaid program coverage of audio-only telehealth services was limited. During the early stages of the pandemic, Medicaid beneficiaries were significantly less likely to complete telehealth visits compared to commercially insured patients. This was likely due to a series of obstacles, including: lack of access to high-quality broadband, a device with video capability, requisite digital skills, and private space to conduct the visit.
For example, in 2019, roughly one in four Medicaid enrollees lived in a home without internet or with limited computer access. That said, Medicaid beneficiaries do not have significantly less access to devices with video capability (such as smartphones) than other patient populations, suggesting network connectivity poses more of a barrier than device access. Even further, nearly 50 percent of low-income patients in the US may not have requisite digital health literacy to use virtual telehealth. However, considering that 86 percent of Medicaid beneficiaries own a smartphone, it may be inferred that many more have sufficient digital literacy to engage in audio-only care rather than audio-visual telehealth. Network connectivity and low rates of digital literacy are two barriers that highlight the importance of creating the infrastructure to deliver and measure audio-only visits is of increased necessity.
It was in this context that, once the pandemic struck, Medicaid agencies changed policies to augment access to telehealth services. For example, 17 state Medicaid agencies expanded reimbursement to include multiple modalities of telehealth, including audio-only. These changes particularly supported patient populations who had transportation, childcare, employment, or income barriers that prevent in-person care—challenges that are more prevalent in the Medicaid population. These policy innovations narrowed the reimbursement gap among in-person, audio-only, and audio-visual visits.
In fact, the Department of Health and Human Services (HHS) recently investigated differences in patient populations who receive telehealth audio-only versus audiovisual use in 2021. For telehealth visits, Medicaid beneficiaries were more likely to use audio-only care than were privately insured patients (35.1 percent versus 45.5 percent). They discovered that compared to White patients, who used audio-only care for 38.1 percent of their telehealth visits, Latino, Black, and Asian patients did so at rates of 49.3 percent, 46.4 percent, and 48.7 percent, respectively. Patients with less than a high school education used it at 61.9 percent of their telehealth visits, compared to those with greater than a bachelor’s degree, who did such at a rate of only 32.6 percent. Across income brackets, there is an inverse relationship between household income and audio-only telehealth use.
As the use of audio-only telehealth became more widespread among Medicaid beneficiaries, state Medicaid leaders needed a mechanism to measure clinical outcomes, health care costs, and patient experiences related to audio-only telehealth. Providers also needed a dedicated billing construct that could be used across public and private payers to streamline billing processes.
Until recently, such mechanisms simply did not exist.
And so, due to these insufficient coding constructs, several Medicaid medical directors spearheaded an application to the American Medical Association (AMA) to create a Current Procedural Terminology (CPT) modifier that would specifically designate audio-only services. In September 2021, the AMA CPT Editorial Panel accepted the addition of the CPT Modifier 93 code for synchronous audio-only telehealth, and the code became active on January 1, 2022. This article provides an overview of the rationale for and process of creating the CPT Modifier 93 code.
Potential Benefits Of Audio-Only CPT Modifier
Why was the creation of a new audio-only modifier necessary? Several reasons: data collection, policy implementation, health care equity, widespread need, and service specificity.
The CPT 93 modifier permits differentiation among audio-only, audiovisual, and in-person care at the administrative level, which subsequently allows health service researchers to monitor and evaluate the use and clinical efficacy among these methods of care delivery.
Prior to the introduction of this modifier, such high-quality analyses were impossible to do at scale. Along with the increase in all modalities of telehealth use since the COVID-19 public health emergency (63 fold increase year over year between 2019 and 2020), a survey performed by HHS (across all 50 states and the District of Columbia) discovered that 45.5 percent of all telehealth usage amongst Medicaid beneficiaries was audio-only. Taking things one step farther, several state legislatures including Washington, Connecticut, and New York have recently passed laws mandating or allowing coverage for audio-only services.
Audio-only telehealth is being highly used, therefore having a mechanism to collect related data is vital.
Implementing this modifier will serve as a tool for policy makers to make informed adjustments in policy around patients who use audio-only services. Implementation of this modifier will also enable claims-based research to monitor for disparities between audiovisual and audio-only care to ensure that all modalities of telehealth are provided in a sustainable, equitable, and high-quality fashion. Additionally, because different states have implemented varying strategies to cover audio-only services during the COVID-19 public health emergency (PHE), the CPT 93 modifier will help health services researchers and policy makers discern the differences between coverage approaches, information that will be crucial in standardizing telehealth data collection/storage across states.
From a coding perspective, adding an audio-only modifier to existing and widely used CPT codes is a far more feasible option than alternatives such as individual payers developing their own coding modifiers. That approach would become unreasonably burdensome on providers who would subsequently have to learn and bill using the system established by each payer.
Previous Codes Did Not Suffice
While CPT codes for services provided through telephone exist, they do not specify the enormous range of behavioral health services, therapies, maternity-related care, post-operative guidance, and other services that have been successfully delivered via audio-only technology since the COVID-19 PHE. For example, CPT code 99441 represents a “telephone evaluation and management service; 5–10 minutes of medical discussion,” which gives no specificity regarding what type of care was delivered. In comparison, the CPT 93 modifier can be attached to theoretically any billing code that is permitted under law, thus allowing for more precise tracking and more useful follow-up research.
Prior to the introduction of the CPT 93 modifier, there were seldom CPT codes that could be used to represent audio-only telehealth for specific services. Even though audio-only telehealth has been delivered at high rates, states have only been able to use temporary or workaround solutions to bill for audio-only services. For example, the Healthcare Common Procedure Coding System (HCPCS) Level II code for crisis response (CR) has been used by some states to support audio-only services during the COVID-19 pandemic. In the two and a half years since the pandemic began, however, the use of audio-only to provide health services has become normalized and may in fact now be expected by Medicaid providers and beneficiaries—a reality for which the CR code, and its temporary application, was not designed. The CPT 93 solves this challenge on a national scale.
Another prior attempt to capture audio-only telehealth was the CPT modifier 95 that only indicated a telehealth service and did not differentiate between audio-only and audio-visual care. HCPCS Level II code “G0” has also been used; however, it indicates a telehealth service for diagnosis, evaluation, or treatment specific to symptoms of an acute stroke. Furthermore, CPT code 99401 can be used to reflect counseling services that may be provided via audio-only care; however, this code failed to capture all the nuance of the amount of time of care was delivered.
At the end of the COVID-19 PHE, the Centers for Medicare and Medicaid Services (CMS) plans to add the “FQ” modifier on claims for HCPCS code G2080 for counseling and therapy provided using audio-only telecommunications. The HCPCS G2080 code refers to when one provides therapy services that largely exceed the amount listed in the patient’s individualized treatment plan for medication assisted treatment for opioid use disorder. This modifier exists solely for CMS’s Opioid Treatment Program and fails to account for other indications for audio-only telehealth. Creating a CPT modifier that is applicable to all service types simplifies the codification and measurement of audio-only care across all payer types.
Conduct More Research On Audio-Only Telehealth
Researchers, provider organizations, and policy makers must investigate and ensure that audio-only telehealth drives strong clinical outcomes. Telephone-focused care has been an important part of primary care; however, much of it was after hours, unmeasured, and not reimbursed. There is strong evidence on audio-only telehealth’s efficacy in prenatal visits and insomnia, for example. A randomized clinical control trial in a patient population of the Kaiser Permanente Washington system received audio-only cognitive behavioral therapy through the telephone demonstrated a significant benefit in improving sleep, fatigue, and osteoarthritis-associated pain. A cohort study amongst pregnant women in the Parkland Health System in Texas found that audio-only perinatal visits were not associated with changes in perinatal outcomes when compared to in-person visits in a vulnerable population. While these data are encouraging, they are sparse. Measurement of a CPT modifier may streamline the research methods used in these studies. Researchers must continue to investigate the efficacy of specific therapies when delivered via audio-only modalities.
While audio-only telehealth solves several problems in health care, there are also several risks such as its potential use for inappropriate clinical indications and the risk that some may see an opportunity to overbill. An audio-only modifier—and therefore a more granular characterization of telehealth modalities—may help assuage concerns about fraud, waste, and abuse, removing existing ambiguity about the impact of different telehealth modalities on outcomes.
We also know that the quality and value of these delivery modalities may vary according to the different demographics being served, including factors such as age, insurance status, payer, income, and region, among many others. Such modalities will likely vary between acuity of patient’s indication for care. Only by studying these differences amongst modalities and the populations served, can we ensure that the care delivered is equitable and valuable.
Implementing the 93 modifier is a vital step toward enabling health services researchers to urgently pursue research questions that inform evidence-based policy about the best use of audio-only telehealth—especially amongst the Medicaid population. It is also essential to ensuring that the growth of audio-only health care does not create a two-tiered system between private insurance and Medicaid. For example, audio-only care may in fact be lower quality or lower value compared to audiovisual care or in-person care—although, further investigation is necessary to understand these differences. Considering that audio-only care helps remove barriers to care for underresourced patient populations, inappropriate use of audio-only care may further exacerbate the already large inequities in health care—a concern raised by both clinicians and patients. This reliance on audio-only care may also hamstring innovations that can improve the quality and access to audiovisual telehealth or in-person care. Clearly, there are legitimate concerns about the equity of audio-only health. To resolve them, more precise data and extensive investigations are necessary: Both of which will be enabled by the implementation of the CPT 93 modifier.
An Opportunity For Action
The new audio-only CPT 93 modifier provides meaningful potential benefits to combat barriers to care that were compounded during the COVID-19 pandemic. The new code creates a potent opportunity for conducting rigorous research into audio-only telehealth to inform federal- and state-level policy around equitable telehealth delivery.
But to make the most of this opportunity, regulators, payers, providers, and researchers must take steps to increase adoption and evaluation of the audio-only modifier. To catalyze this work, large health systems should consider leading the adoption of the CPT 93 modifier while also encouraging local private providers to do the same. Payers and purchasers should consider requiring modifier submission, a step that would also facilitate further research into the field with minimal additional administrative burden on providers. Federal health agencies have a role as well. For example, the Agency for Healthcare Research and Quality (AHRQ) may increase awareness of the modifiers amongst affiliated researchers or those who use AHRQ databases while the Health Resources and Services Agency may require community health centers they fund to use the new modifier.
The authors would like to thank Dr. John Morgan and Amanda Brodt for their contributions to preparing this paper. Dr. Ostrovsky is an investor in the following companies, some of which provide telehealth services: https://www.socialinnovationventures.com. However, there are no direct conflicts of interest.