We are reviewing 2020 eCQM Telehealth Guidance and seeking some clarification for QRDA1 modifier printing part.
1) If the EMR has a way to identify telehealth encounter but if the provider/office staff has not documented the telehealth modifier on the encounter, we are mapping these televisit encounter to modifier "95" and printing in the QRDA1 file. Would this be appropriate?

2) Is there an option to use nullflavor if the modifier code is not available but can still use name of code as VR based on the telehealth flag (this flag is present in our system for telehealth encounters) ?