Telehealth Billing, Coding and Reimbursement Updates For Medicare

Released May 1, 2020

Rural Provider Relief Fund: All RHCs To Receive a Minimum of $100,000

  1. Every federally certified Rural Health Clinic – including Pediatric RHCs – will receive funds from this distribution.
  2. Rural Health Clinics will not need to apply.  Your clinic-specific allocation will be automatically deposited in your account (presuming you have an ACH on file with Medicare).  If you do NOT receive money from CMS electronically but instead, get checks, then it will take longer to get the money.
  3. The deposit should appear in the RHCs account in the middle of next week (on or around 5/6).
  4. For Independent RHCs the money will come directly to the RHC as enrolled in the Medicare or Medicaid program.
  5. For Provider-based RHCs that are owned by rural hospitals or CAHs, the money will be included in the distribution for the rural hospital/CAH account.
  6. For Provider-based RHCs that are owned by non-rural hospitals, the money will be sent to the parent hospital.
  7. The amount each RHC receives will vary depending on the operating expenses of the clinic but every RHC will receive no less than $100,000, regardless of expenses. Amounts above $100,000 will be based on operating expenses.
  8. Each CAH and rural hospital will receive an amount that will vary depending on the operating expenses of the rural hospital/CAH but every rural hospital/CAH will receive no less than $1,000,000 for the hospital and no less than $100,000 for each RHC attached to that hospital.

The Average distribution per RHC will be $162,000.  The average distribution for rural hospitals/CAHs will be $4,000,000. We do not know what data is being used to calculate the RHCs average operating expenses but we are expecting an update on this soon.

Released April 30, 2020

New and Expanded Flexibilities for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) During the COVID-19 Public Health Emergency (PHE) 

  1. For telehealth distant site services furnished between January 27, 2020, and June 30, 2020, RHCs must report HCPCS code G2025 on their claims with the CG modifier. Modifier “95” may also be appended, but is not required.
  2. These claims will be paid at the RHC’s all-inclusive rate (AIR), and automatically reprocessed beginning on July 1, 2020, at the $92.03 rate. RHCs do not need to resubmit these claims for the payment adjustment.
  3. Beginning July 1, 2020, RHCs should no longer put the CG modifier on claims with HCPCS code G2025.
  4. Effective March 1, 2020, these services include CPT codes 99441, 99442, and 99443, which are audio-only telephone evaluation and management (E/M) services. RHCs and FQHCs can furnish and bill for these services using HCPCS code G2025 ($92 reimbursement)
  5. To bill for these services, at least 5 minutes of telephone E/M service by a physician or other qualified health care professional who may report E/M services must be provided to an established patient, parent, or guardian. 
  6. These services cannot be billed if they originate from a related E/M service provided within the previous 7 days or lead to an E/M service or procedure within the next 24 hours or soonest available appointment.
     

Released April 25, 2020

 

Released April 17, 2020

New and Expanded Flexibilities for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) During the COVID-19 Public Health Emergency (PHE) 

  • Distant site telehealth services can be furnished by any health care practitioner working for the RHC or the FQHC within their scope of practice.
  • Practitioners can furnish distant site telehealth services from any location, including their home, during the time that they are working for the RHC or FQHC
  • Providers can furnish any telehealth service that is approved as a distant site telehealth service under the Physician Fee Schedule (PFS)
  • Covered Telehealth Services for PHE for the COVID-19 pandemic, effective March 1, 2020 (ZIP)
  • Payment to RHCs and FQHCs for distant site telehealth services is set at $92
  • Effective January 27, 2020, thru June 30, 2020, RHCs and FQHCs must put Modifier “95” on the outbound claim
    • These claims will be automatically reprocessed in July when the Medicare claims processing system is updated with the new payment rate. 
    • RHCs and FQHCs do not need to resubmit these claims for the payment adjustment.
  • For telehealth distant site services furnished between July 1, 2020, and the end of the COVID19 PHE, RHCs and FQHCs will use an RHC/FQHC specific G code, G2025
  • If the COVID-PHE is in effect after December 31, 2020, this rate will be updated based on the 2021 PFS average payment rate for these services, weighted by volume for those services reported under the PFS.

Released April 7, 2020

Waiver of Coinsurance and Deductibles for Additional COVID-19 Related Services:

The Families First Coronavirus Response Act waives cost-sharing under Medicare Part B (coinsurance and deductible amounts) for Medicare patients for COVID-19 testing-related services. Cost-sharing does not apply for COVID-19 testing-related services, which are medical visits that result in an order for or administration of a COVID-19 test; are related to furnishing or administering such a test or to the evaluation of an individual for purposes of determining the need for such a test. For more details on the types of services covered please see resource link below.

  1. For services furnished on March 18, 2020, and through the end of the PHE, providers and suppliers that bill Medicare for Part B services should use the CS modifier on applicable claim lines to identify the service as subject to the cost-sharing wavier for COVID-19 testing-related services and should NOT charge Medicare patients any co-insurance and/or deductible amounts for those services.
  2. For professional claims, physicians and practitioners who did not initially submit claims with the CS modifier must notify their Medicare Administrative Contractor (MAC) and request to resubmit applicable claims with dates of service on or after 3/18/2020 with the CS modifier to get 100% payment. 
  3. For institutional claims, providers, including hospitals, CAHs, RHCs, and FQHCs, who did not initially submit claims with the CS modifier must resubmit applicable claims submitted on or after 3/18/2020, with the CS modifier to visit lines to get 100% payment

Resource: Families First Coronavirus Response Act Waives Coinsurance and Deductibles for Additional COVID-19 Related Services

For Dates Of Service On, Or After, March 1, 2020

List of covered Medicare CPT codes for Telehealth expanded:

  1. Covered Telehealth Services for PHE for the COVID-19 pandemic, effective March 1, 2020. New codes include:
  2. 99281-99285 Emergency Department Visits
  3. 99218-99220 Initial Observation, 99224-99226 Subsequent Observation, 99217 Observation Discharge Day Management, and 99234-99236 Same Day Observation  
  4. 99221-99223 Initial hospital care and 99238-99239 Hospital discharge day management  
  5. 99291-99292 Critical Care Services  
  6. 99468-99476 Inpatient Neonatal and Pediatric Critical Care Initial and Subsequent 
  7. 99477-994780 Neonatal/Low Birth Weight Initial and Continuing Intensive Care Services  
  8. 97161- 97168; 97110, 97112, 97116, 97535, 97750, 97755, 97760, 97761, 92521- 92524, 92507 Therapy Services, Physical and Occupational Therapy

Place of Service (POS) on the Claim for updated reimbursement to be at same rate as in-person office visits. Previously, payment for telehealth services was tied to (typically lower) facility rate:

  1. To receive payment at same rate as in-person office visits, use same place of service (e.g. 11 or 22) code that would have been reported had service been furnished in person
  2. CPT telehealth modifier (modifier 95) must be used to indicate service was furnished via telehealth
  3. CMS does allow providers to continue to use POS 02 for all telehealth services, however, this will result in decreased reimbursement under the Facility Fee Schedule. Commercial payors may have different guidelines, so check with your respective payors on this.

Waiver expanded list of eligible providers to provide services and be reimbursed to include:

  1. Physical Therapists
  2. Occupational Therapists
  3. Speech Language Pathologist

Frequency Limitations: There are now no frequency limitations on the following:

  1. Subsequent inpatient visit (99231-99233) not limited to once every 3 days
  2. Subsequent skilled nursing visit (99307-99310) not limited to once every 30 day
  3. Critical care consult codes (G0508-G0509) not limited to once per day 

Consent:

  1. Annual patient consent does not have to be obtained prior to the initial telehealth visit. Consent should not interfere with patient care and can be obtained during or after the visit if necessary.

Physician Supervision:

  1. CMS has temporarily augmented the definition of direct physician supervision to include virtual supervision. During the current public health emergency, the provision requires that the physician use real-time audio with video technology while supervising.

Virtual Check Ins and E-Visits:

  1. Virtual Check-Ins (G2010-G2012) and E-visits (G2061-G2063) can now be performed for both new and established patients. 
  2. These codes can also now be billed by LCSWs, clinical psychologists, PTs, OTs, and SLPs if needed. CMS also requires that therapists use the appropriate therapy modifier (GO, GP, GN) for their services.

Telephones services updates:

  1. Due to the COVID-19 pandemic, telephone only E/M visits (previously non-covered and not payable by Medicare) are now approved for new and established patients. Medicare is allowing telephone only E/M codes for new and established patients.
  2. CPT codes: 99441-99443 and 98966-98968

Provider Enrollment:

  1. CMS has established toll-free hotlines to simplify and expedite provider enrollment. See MAC information at: https://www.cms.gov/files/document/provider-enrollment-relief-faqs-covid-19.pdf

Rural Health Clinics (RHC) Telehealth updates:

RHCs Approved “Distant” Site Telehealth Providers:

  1. As part of the CARES Act, Congress has authorized Rural Health Clinics to be the “distant site” for telehealth visits. Until now, RHCs could only be the originating site for these visits. 
  2. CMS is working on the guidance necessary to allow RHCs to begin submitting claims for these visits (effective March 27th).
  3. Guidance is still pending from CMS on how RHCs should bill for telehealth visits and what the reimbursement will be. Current RHC telehealth claims will need to be held pending the release of information Additional info on the impact to cost reporting is also pending.

Expanded services that can be included in the payment for HCPCS code G0071, and update the payment rate to reflect the addition of these services. Specifically, we are adding the following three CPT codes:

  1. 99421 (Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes)
  2. 99422 (Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 11-20 minutes)
  3. 99423 (Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 21 or more minutes)
  4. Effective for services furnished on or after March 1, 2020 and throughout the the COVID pandemic, the payment rate for HCPCS code G0071 will be the average of the PFS national non-facility payment rate for HCPCS code G2012 (communication technology-based services), HCPCS code G2010 (remote evaluation services), CPT code 99421, CPT code 99422, and CPT code 99423. The RHC and FQHC face-to-face requirements are waived for these services.

Additional Resources To Support Your During COVID-19​

 

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