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COVID-19 Temporary Regulatory Changes Posted March 31, 2020

Craneware® Insights Regulatory Updates – CWI1220 (06 April 2020)


COVID-19 Temporary Regulatory Changes Posted March 31, 2020

On March 31, 2020, CMS posted an MLN Connects “Special Edition” article entitled “COVID-19: Regulatory Changes, Telehealth Billing, and Specimen Collection Codes”. CMS also posted an interim final rule entitled “Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency” in which much of this information is discussed in more detail. We have provided a link to the interim final rule under the “Background” section of this article.

Provider Types Affected

Critical Access Hospitals
OPPS Hospitals
Provider-Based FQHC
Provider-Based Rural Health Clinics

Departments/Areas Affected

Ambulatory Surgery
Business Office
Compliance / Revenue Integrity
Emergency Department
Laboratory – General
HIM/Medical Records

What You Need to Know

CMS posted an MLN Connects article that contains information about COVID-19 regulatory changes, telehealth, and specimen collection codes. As this information is changing almost daily, we are providing a summary of the information as it was presented on March 31, 2020.

Under President Trump’s direction, CMS has issued a number of temporary regulatory waivers and new rules to allow health care providers the flexibility needed to respond to the 2019 Novel Coronavirus (COVID-19) pandemic. These temporary changes will apply to the entire U.S. health care system for the duration of the emergency declaration.

Increase Hospital Capacity

CMS is taking the following actions to enable an increase in “hospital capacity”:

  • Ambulatory surgery centers may contract with local health care systems to provide hospital services, or they can enroll and bill as hospitals during the emergency declaration as long as they are not inconsistent with their state’s Emergency Preparedness or Pandemic Plan. These types of facilities may provide services typically provided by hospitals such as cancer procedures, trauma surgeries, and other essential surgeries.
  • Non-hospital buildings and spaces may be used for patient care and quarantine sites. The location must be approved by the state and it must ensure the safety and comfort of patients and staff.
  • Hospitals, laboratories, and other entities may perform COVID-19 lab tests on people at home and in other community-based settings outside of the hospital.  These testing sites are exclusively for the purpose of identifying COVID-19-positive patients in a safe environment. In addition, hospital emergency departments may test and screen patients for COVID-19 at drive-through and off-campus test sites.
  • Physician-owned hospitals can temporarily increase the number of their licensed beds, operating rooms, and procedure rooms to accommodate patient surge during the public health emergency.
  • Hospitals can bill for services provided outside their actual facility. Emergency departments of hospitals can use telehealth services to quickly assess patients to determine the most appropriate site of care. New rules allow patients to be screened at alternate treatment and testing sites which are not subject to the Emergency Medical Labor and Treatment Act (EMTALA) as long as the national emergency remains in force.

Increase Health Care Workforce

Currently, nonessential medical and surgical services are postponed during the public health emergency. CMS is implementing temporary requirements to allow hospitals and health care systems to increase their workforce by removing barriers for physicians, nurses, and other clinicians to be readily hired from the local community, as well as those licensed from other states without violating Medicare rules.

  • Hospitals may use practitioners such as physician assistants and nurse practitioners in accordance with a state’s emergency preparedness or pandemic plan. Where permitted by law, these practitioners may perform services, such as order tests and medications that may have previously required a physician’s order.
  • CMS is waiving the requirements that a Certified Registered Nurse Anesthetist (CRNA) must be under the supervision of a physician, where allowed by state law. This will free up physicians from the supervisory requirement and expand the capacity for both CRNAs and physicians.
  • Hospitals may provide benefits and support to their medical staff, such as daily meals, laundry service, or child care while the medical staff are engaging in activities that benefit the hospital and its patients.
  • Health care providers may enroll in Medicare temporarily to provide care during the public health emergency.

Patients Over Paperwork

CMS is temporarily eliminating certain paperwork requirements.

  • Respiratory-related devices and equipment will be covered for any medical reason as determined by the clinicians. Currently, these items are covered only under certain circumstances.
  • Hospitals will  not be required to have written policies regarding visitation of patients who are in COVID-19 isolation.
  • CMS is extending reporting deadlines and suspending documentation requests so that providers, health care facilities, Medicare Advantage health plans, Medicare Part D prescription drug plans, and states can focus on providing needed care to Medicare and Medicaid beneficiaries affected by COVID-19.


CMS previously expanded telehealth service to Medicare beneficiaries during the public health emergency. The following temporary changes will ensure that patients have access to physicians and other providers while remaining at home.

  • Telehealth visits include emergency department visits, initial nursing facility and discharge visits, home visits, and therapy services, which must be provided by a clinician that is allowed to provide telehealth.
  • Telehealth visits may be with new or established patients.
  •  Providers may bill for telehealth visits at the same rate as in-person visits.
  • Telehealth services will fulfill many face-to-face visit requirements for clinicians to see patients in inpatient rehabilitation facilities, hospice, and home care.
  • Clinicians may provide remote patient monitoring services to patients with acute and chronic conditions, as well as patients with only one disease. CMS provides an example of remote patient monitoring as the monitoring of a patient’s oxygen saturation levels using pulse oximetry.
  • Physicians may supervise their clinical staff using virtual technologies, when appropriate, instead of requiring in-person presence.

Professional Billing for Telehealth Services

The following guidelines pertain to billing professional claims for non-traditional telehealth services with dates of service on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE).

  • For 1500 billing, the place of service (POS) is equal to what it would have been in the absence of a PHE. Traditional Medicare telehealth services professional claims should reflect the designated POS code 02-Telehealth, to indicate the billed service was furnished as a professional telehealth service from a distant site.
  • Use modifier 95 to indicate that the service rendered was a telehealth service.
  • CMS is not requiring the “CR” modifier on telehealth services.
  • Two additional scenarios exist where modifiers are required on Medicare telehealth professional claims:
    • GQ modifier: Furnished as part of a federal telemedicine demonstration project in Alaska and Hawaii using asynchronous (store and forward) technology; and
    • G0 modifier: Furnished for diagnosis and treatment of an acute stroke.

Institutional Claims

There are no billing changes for institutional claims.

  • Critical access hospital method II claims should continue to be billed with modifier GT.
New Specimen Collection Codes for Laboratories

CMS has established two new HCPCS codes that are billable by independent clinical diagnostic laboratories for COVID-19 testing specimen collection, for dates of service on or after March 1, 2020:

  • G2023 – Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), any specimen source; and
  • G2024 – Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), from an individual in a skilled nursing facility or by a laboratory on behalf of a home health agency, any specimen source.

Action Needed

CMS is posting COVID-19 information on a daily basis and the content of the information remains “fluid”. The Craneware Insights articles provide an overview of the CMS information as it is presented at that time. Questions pertaining to the temporary CMS program changes should be directed to your MAC.

Providers and suppliers should review the information contained in the MLN Matters article in its entirety. This information should be disseminated to staff responsible for telehealth services professional billing and laboratory staff, if applicable. The new HCPCS codes should be incorporated into the chargemaster and charge capture tools if the laboratory qualifies as an independent laboratory.

In addition to the MLN Matters article, CMS has posted an interim final rule, which provides information on the temporary changes in regulations due to the COVID-19 emergency. Craneware will be issuing an Insights article on the interim final rule. We would also recommend accessing Craneware’s for COVID-19 coding and billing information.

Effective Date

01 March 2020


CMS Definition of “Independent Laboratory” – Medicare Claims Processing Manual (100-04), chapter 16, section 10.1:

CMS Emergencies Webpage:

“Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency” Interim Final Rule:


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