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© 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com
Presented by
Megan Smith
HRG Exec Director, Quality & Training
COVID-19 Support: Expanded Telehealth
Billing Using Current CMS Guidance
© 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com
Telemedicine
Healthcare and education provided remotely using
telecommunications technology
Virtual Check-ins
Brief technology communication for established patients.
Must be unrelated to medical visit within previous 7 days
and/or does not lead to a medical visit in next 24 hours
Store-and-Forward
Two-way communication in which recorded information
from patient is sent to the provider for review and follow up
Originating Sites
Location of an eligible Medicare beneficiary at the time the
service is furnished via a telecommunication
Distant Site Practitioners
Practitioners at the distant site who may furnish and receive
payment for covered telehealth services
KEY INDUSTRY TERMS
© 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com
• Originating site restriction waived; dated back to March 6th
• Fee schedule additions dated back to 3/1/2020
• Patient Prior Relationship Waived for telehealth
• Providers Can Use Additional audio/video Technology
• Flexibility to Reduce or Waive Patient Cost Share
• CMS waiving video requirements for certain E&Ms
• RHC/FQHC can furnish and bill services as distant site
March 2020
Changes Under Waiver 1135
© 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com
• Waiving distant site practitioner limitations to include
PT/OT therapists and SLP
• Patients’ home can be billed as originating site if
patient is registered as Outpatient of hospital
outpatient department (HOD)
• Reimbursable audio only services expanded to include
behavioral health and education services
• Waived requirements for physician privileges
April 2020
Changes Under Waiver 1135 Continued…
© 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com
Method I CAH
• Billed on 1500 claim form
• Place of Service (POS) equal to what it would have been in absence of PHE
• Appropriate CPT or HCPCs code
• Append modifier 95 to indicate telehealth service during PHE
CAH DISTANT SITE BILLING
Method II CAH
• Billed on UB04 for with type of bill (TOB) 085X
• Appropriate CPT or HCPC code
• Revenue code 096x, 097x or 098X
• GT Modifier appended to E/M line
• Append modifier 95 to indicate telehealth service during PHE
© 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com
Dates of service 1/27/2020 – 6/30/2020
• Billed on UB04 claim form with type of bill (TOB) 071X
• Revenue code 052X
• HCPCs code G2025: Services that were furnished via telehealth
• Append CG modifier
• Modifier 95 showing as optional at this time
RHC DISTANT SITE BILLING
Dates of service AFTER July 1, 2020
• Billed on UB04 claim form with type of bill (TOB) 071X
• Revenue code 052X
• HCPCs code G2025: Services that were furnished via telehealth
• Modifier 95 showing as optional at this time
© 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com
Qualifying Visit Services Furnished 1/27/2020 -6/30/2020
• Billed on UB04 with Type of bill (TOB) 071X | Revenue code 052X
• Include three HCPCs/CPT codes:
1) Applicable FQHC PPS G payment code
2) HCPCs/CPT describing services furnished
3) HCPCs G2025
• Append modifier 95 to HCPCs/CPT services code and G2025 to indicate telehealth
service during PHE
FQHC DISTANT SITE BILLING
© 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com
Services Furnished AFTER July 1st or FQHC Non Qualifying Visits
Prior to July 1st 2020*
• Billed on UB04 with Type of bill (TOB) 071X | Revenue code 052X
• HCPCs G2025
• Modifier 95 showing as optional
*When furnishing services via telehealth that are not FQHC qualifying visits, FQHCs should
hold these claims until July 1, 2020 then bill with G2025 only
FQHC DISTANT SITE BILLING
© 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com
• RHCs and FQHCs for distant site payment set at $92.03; the average
amount for all PFS telehealth services, weighted by volume for those
services reported under the PFS
• Claims paid at the RHC’s all-inclusive rate (AIR), will automatically reprocess
beginning on July 1, 2020
• RHCs/FQHCs do not need to resubmit these claims for the payment adjustment
RHC/FQHC DISTANT SITE PAYMENT
© 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com
• CMS will pay reasonable costs for specified categories of evaluation and
management (E/M) services resulting in an order for or administration of a
COVID-19 test
• RHCs and FQHCs must waive the collection of co-insurance from
beneficiaries and report using modifier “CS” on the claim service line
• Claims paid with the coinsurance applied will automatically reprocess
beginning on July 1, 2020
Coinsurance should not be collected from beneficiaries if the
coinsurance is waived
CS MODIFIER
© 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com
INTERNAL RESOURCES
Ensure Billing Success During
Rapid Changes
SharePoint: One-stop repository for
Telehealth billing changes
COVID-19 At A Glance infographic
© 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com
CMS FAQ, dated March 17th, 2020
https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf
MLN SE20011; Revised
https://www.cms.gov/files/document/se20011.pdf
CMS MLN Matters #SE20016: FQHC/RHC Telehealth Expansion
https://www.cms.gov/files/document/se20016.pdf
State Specific Telehealth Payer Guidance
https://www.cchpca.org/telehealth-policy/current-state-laws-and-reimbursement-policies
Center for Connected Health Policy; National Telehealth Policy Resource Center
https://www.cchpca.org/resources/covid-19-telehealth-coverage-policies
ADDITIONAL COVID-19 TELEHEALTH RESOURCES

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Expanded telehealth updates covid 19

  • 1. © 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com Presented by Megan Smith HRG Exec Director, Quality & Training COVID-19 Support: Expanded Telehealth Billing Using Current CMS Guidance
  • 2. © 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com Telemedicine Healthcare and education provided remotely using telecommunications technology Virtual Check-ins Brief technology communication for established patients. Must be unrelated to medical visit within previous 7 days and/or does not lead to a medical visit in next 24 hours Store-and-Forward Two-way communication in which recorded information from patient is sent to the provider for review and follow up Originating Sites Location of an eligible Medicare beneficiary at the time the service is furnished via a telecommunication Distant Site Practitioners Practitioners at the distant site who may furnish and receive payment for covered telehealth services KEY INDUSTRY TERMS
  • 3. © 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com • Originating site restriction waived; dated back to March 6th • Fee schedule additions dated back to 3/1/2020 • Patient Prior Relationship Waived for telehealth • Providers Can Use Additional audio/video Technology • Flexibility to Reduce or Waive Patient Cost Share • CMS waiving video requirements for certain E&Ms • RHC/FQHC can furnish and bill services as distant site March 2020 Changes Under Waiver 1135
  • 4. © 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com • Waiving distant site practitioner limitations to include PT/OT therapists and SLP • Patients’ home can be billed as originating site if patient is registered as Outpatient of hospital outpatient department (HOD) • Reimbursable audio only services expanded to include behavioral health and education services • Waived requirements for physician privileges April 2020 Changes Under Waiver 1135 Continued…
  • 5. © 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com Method I CAH • Billed on 1500 claim form • Place of Service (POS) equal to what it would have been in absence of PHE • Appropriate CPT or HCPCs code • Append modifier 95 to indicate telehealth service during PHE CAH DISTANT SITE BILLING Method II CAH • Billed on UB04 for with type of bill (TOB) 085X • Appropriate CPT or HCPC code • Revenue code 096x, 097x or 098X • GT Modifier appended to E/M line • Append modifier 95 to indicate telehealth service during PHE
  • 6. © 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com Dates of service 1/27/2020 – 6/30/2020 • Billed on UB04 claim form with type of bill (TOB) 071X • Revenue code 052X • HCPCs code G2025: Services that were furnished via telehealth • Append CG modifier • Modifier 95 showing as optional at this time RHC DISTANT SITE BILLING Dates of service AFTER July 1, 2020 • Billed on UB04 claim form with type of bill (TOB) 071X • Revenue code 052X • HCPCs code G2025: Services that were furnished via telehealth • Modifier 95 showing as optional at this time
  • 7. © 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com Qualifying Visit Services Furnished 1/27/2020 -6/30/2020 • Billed on UB04 with Type of bill (TOB) 071X | Revenue code 052X • Include three HCPCs/CPT codes: 1) Applicable FQHC PPS G payment code 2) HCPCs/CPT describing services furnished 3) HCPCs G2025 • Append modifier 95 to HCPCs/CPT services code and G2025 to indicate telehealth service during PHE FQHC DISTANT SITE BILLING
  • 8. © 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com Services Furnished AFTER July 1st or FQHC Non Qualifying Visits Prior to July 1st 2020* • Billed on UB04 with Type of bill (TOB) 071X | Revenue code 052X • HCPCs G2025 • Modifier 95 showing as optional *When furnishing services via telehealth that are not FQHC qualifying visits, FQHCs should hold these claims until July 1, 2020 then bill with G2025 only FQHC DISTANT SITE BILLING
  • 9. © 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com • RHCs and FQHCs for distant site payment set at $92.03; the average amount for all PFS telehealth services, weighted by volume for those services reported under the PFS • Claims paid at the RHC’s all-inclusive rate (AIR), will automatically reprocess beginning on July 1, 2020 • RHCs/FQHCs do not need to resubmit these claims for the payment adjustment RHC/FQHC DISTANT SITE PAYMENT
  • 10. © 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com • CMS will pay reasonable costs for specified categories of evaluation and management (E/M) services resulting in an order for or administration of a COVID-19 test • RHCs and FQHCs must waive the collection of co-insurance from beneficiaries and report using modifier “CS” on the claim service line • Claims paid with the coinsurance applied will automatically reprocess beginning on July 1, 2020 Coinsurance should not be collected from beneficiaries if the coinsurance is waived CS MODIFIER
  • 11. © 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com INTERNAL RESOURCES Ensure Billing Success During Rapid Changes SharePoint: One-stop repository for Telehealth billing changes COVID-19 At A Glance infographic
  • 12. © 2020 Healthcare Resource Group, Inc. ALL RIGHTS RESERVED. hrgpros.com CMS FAQ, dated March 17th, 2020 https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf MLN SE20011; Revised https://www.cms.gov/files/document/se20011.pdf CMS MLN Matters #SE20016: FQHC/RHC Telehealth Expansion https://www.cms.gov/files/document/se20016.pdf State Specific Telehealth Payer Guidance https://www.cchpca.org/telehealth-policy/current-state-laws-and-reimbursement-policies Center for Connected Health Policy; National Telehealth Policy Resource Center https://www.cchpca.org/resources/covid-19-telehealth-coverage-policies ADDITIONAL COVID-19 TELEHEALTH RESOURCES

Editor's Notes

  1. Patient’s were required to utilize telehealth services sitting within the walls of a healthcare facility – know as the Originating Site CMS announced 85 additional codes on March 28th. Codes include ED E&Ms, Home visits, Hospital discharge New and established patients’ can seek telemedicine – for any DX – not just COVID-19 related. HHS will not be conducting audits on claims submitted during PHE Office of Civil Rights announced they will waive potential HIPAA penalties for good faith use of non-public facing applications such as Apple Face Time, Skype, Microsoft Teams. OIG gave the option for providers and insurance payers to reduce or waive fees during this time. CMS is currently waiving all out of pocket for COVID-19 related testing These additional services were then added to the list of approved telehealth services
  2. Prior to this change, only doctors, nurse practitioners, physician assistants, and certain others could deliver telehealth services. Speech Language Pathologists Examples of such services include counseling and educational service as well as therapy services Medicare beneficiaries without access to audio/video technology can use audio only for certain telephone E&M service. CMS is also increasing payments for these telephone visits to match payments for similar office and outpatient visits. This would increase payments for these services from a range of about $14-$41 to about $46-$110. The payments are retroactive to March 1, 2020. To address workforce concerns, CMS is waiving requirements to allow physicians whose privileges will expire to continue practicing. Also allow new physicians to practice before full medical staff review and approval
  3. Distant site telehealth services can be furnished by any health care practitioner working for the RHC or the FQHC within their scope of practice Furnish telehealth services from any location, including their home Furnish any telehealth service that is approved as a distant site telehealth service under the Physician Fee Schedule (PFS)
  4. Because these changes in policy were made on an emergency basis, CMS needs to implement changes to claims processing systems in several stages
  5. Because these changes in policy were made on an emergency basis, CMS needs to implement changes to claims processing systems in several stages