CMS has waived certain Medicare restrictions on digital communication in light of the COVID-19 pandemic, including "remote evaluation of recorded video and/or images."
The HCPCS code for the service, G2010, is used only for asynchronous — also called store-and-forward — technologies that involve prerecorded, patient-generated still or video images that an established patient has submitted electronically. After you review and interpret the image or video, you must follow up with the patient within 24 business hours of receiving the file. This can be done via telephone, audio/video communication, secure text messaging, email, or patient portal communication. If the image is insufficient to enable you to make a determination, you cannot bill for it.
Although the code descriptor refers to an established patient that you currently are treating under a plan of care, CMS says it is "exercising enforcement discretion" on an interim basis and will not conduct reviews to consider whether this service is furnished to established patients. However, APTA advises you to continue to comply with your state practice act and any other applicable state or local laws, which generally require the PT to have evaluated a patient before providing any recommendations or care.