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Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) – Expanded Flexibilities During COVID-19 Public Health Emergency

Craneware® Insights Regulatory Updates – CWI1229 (22 April 2020)


Topic

Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) – Expanded Flexibilities During COVID-19 Public Health Emergency

On April 17, 2020, CMS posted a MLN Matters article, #SE20016, in which information is provided concerning Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) during the COVID-19 Public Health Emergency (PHE).

Provider Types Affected

Provider-Based FQHC
Provider-Based Rural Health Clinics
Physicians

Departments/Areas Affected

Business Office
Compliance / Revenue Integrity
Finance
HIM/Medical Records
OP Clinics

What You Need to Know

Section 3704 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) authorized RHCs and FQHCs to furnish distant telehealth services to Medicare beneficiaries for the duration of the COVID-19 PHE. Generally, Medicare telehealth services require interactive audio and video telecommunications system between the practitioner and the patient. RHCs and FQHCs with this capability can immediately provide Medicare telehealth services and be reimbursed for services furnished for the duration of the COVID-19 PHE.

Distant site telehealth services can be furnished by any health care practitioner working for the RHC or FQHC within their scope of practice. Distant site services can be furnished from any location, including the practitioner’s home, during the time they are employed by the RHC or FQHC. Telehealth services must be approved as a distant site telehealth service under the Physician Fee Schedule (PFS). For a list of the approved telehealth services, please access the following CMS link: https://www.cms.gov/files/zip/covid-19-telehealth-services-phe.zip.

CMS is required to develop payment rates for RHC/FQHC telehealth services that are similar to the national average payment rate for comparable telehealth services. The RHC and FQHC payment rate for distant site telehealth services is $92.00.

Telehealth Billing from January 27, 2020 – June 30, 2020

RHCs and FQHCs are required to report Modifier “95” (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) on the claim for telehealth services furnished between January 27, 2020 and June 30, 2020. RHCs will be paid at their all-inclusive rate (AIR) and FQHCs will be paid based on the FQHC Prospective Payment System (PPS).

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.

Telehealth Billing from July 1, 2020

RHCs and FQHCs will be required to use a new HCPCS code (G2025) to identify services furnished via telehealth from July 1, 2020 until the end of the COVID-19 PHE. The new G-code will be paid at the $92 rate. CMS indicates that this payment rate will be updated for CY 2021 if the COVID-19 PHE extends past December 31, 2020.

Cost Reporting

RHCs and FQHCs must report distant site telehealth services on the appropriate cost report form. RHCs must report both originating and distant site telehealth costs on Form CMS-222-17, on line 79 of Worksheet A, in the section titled “Cost Other Than RHC Services”. FQHCs are to report originating and distant site services on Form CMS-224-14, on line 66 of Worksheet A, in the section titled “Other FQHC Services”.

Coinsurance Waiver for Services Related to COVID-19 Testing

CMS will pay reasonable costs for any service related to COVID-19 testing, including applicable telehealth services, for services furnished beginning on March 1, 2020. RHCs and FQHCs must waive the beneficiary coinsurance for services related to COVID-19 testing, including telehealth. Coinsurance should not be collected from Medicare beneficiaries for services in which the coinsurance is waived.

The RHC or FQHC must append modifier “CS” on the service line(s) for which the coinsurance is waived. RHC and FQHCs will be paid with the coinsurance applied. The Medicare Administrative Contractor (MAC) will automatically reprocess these claims beginning on July 1, 2020.

Expansion of Virtual Communication Services

Payment for virtual services now include online digital evaluation and management services (CPT® codes 99421-99422). The HCPCS codes for virtual communication services are G2010 and G2012. These are non-face-to-face, patient-initiated, digital communications using a secure patient portal. RHCs and FQHCs must report virtual communication services with HCPCS code G0071 (Payment for communication technology-based services for 5 minutes or more of a virtual (non-face-to-face) communication between a Rural Health Clinic (RHC) or Federally Qualified Health Center (FQHC) practitioner and RHC or FQHC patient, or 5 minutes or more of remote evaluation of recorded video and/or images by an RHC or FQHC practitioner, occurring in lieu of an office visit; RHC or FQHC only). HCPCS code G0071 may be used alone or with other payable services. The payment rate for G0071 is $24.76 for dates of service on or after March 1, 2020 for the duration of the COVID-19 PHE. MACs will automatically reprocess any claims with G0071 for services furnished on or after March 1, 2020 that were paid before the claims processing system was updated.

Revision of Home Health Agency (HHA) Shortage Requirement for Visiting Nursing Services

RHCs and FQHCs can bill for visiting nursing services furnished by an RN or LPN to homebound individuals under a written plan of treatment in areas with a shortage of home health agencies (HHAs) The area typically served by the RHC and the FQHC service area is determined to have a shortage of HHAs, therefore, no request for this determination is required, effective March 1, 2020 for the duration of the COVID-19 PHE. Before providing the nursing services, CMS requires the RHCs and FQHCs to check the HIPAA Eligibility Transaction System (HETS) to ensure that the patient is not already under a home health plan of care.

Consent for Care Management and Virtual Communication Services

CMS requires beneficiary consent for all services, including non-face-to-face services. During the COVID-19 PHE, beneficiary consent may be obtained at the same time the services are initially furnished. For RHCs and FQHCs, the consent does not require direct supervision and can be obtained by auxiliary staff under general supervision of the RHC or FQHC practitioner. Auxiliary staff may be an employee, independent contractor, or leased employee of the RHC or FQHC practitioner.

Accelerated/Advance Payments

CMS has expanded the current Accelerated and Advance Payment Program. This program is intended to provide the necessary funds when there is a disruption in claims submission and/or claims processing. CMS is authorized to provide accelerated or advance payment for the duration of the PHE to an RHC or FQHC who submits a request to their MAC and meets the required qualifications. Each MAC will review requests and issue payments within seven calendar days of receiving the request. For purposes of the COVID-19 pandemic, CMS has extended the repayment of the accelerated/advance payments to begin 120 days after the date of issuance of the payment. For more information on this process, please access the following link to the Accelerated and Advance Payments Fact Sheet: https://www.cms.gov/files/document/Accelerated-and-Advanced-Payments-Fact-Sheet.pdf.

Action Needed

RHCs and FQHCs should read the MLN article and associated material in their entirety. Staff need to be informed of the billing guidelines for telehealth services beginning January 29, 2020. The chargemaster and charge capture tools should include the new G-code for reporting telehealth services on or after July 1, 2020. Ensure that staff are educated on the use of Modifiers “95” and “CS”.

Staff should also be aware that the coinsurance amount is waived for any service(s) related to COVID-19 testing, including telehealth services, beginning with services furnished on March 1, 2020.

Lastly, ensure that the authorized representative of the RHC or FQHC is aware of the ability to request an accelerated/advance payment from the MAC that services your geographic area.

Effective Date

27 January 2020

Background

Coronavirus Aid, Relief and Economic Security (CARES) Act:

https://www.congress.gov/bill/116th-congress/senate-bill/3548/text

Reference

https://www.cms.gov/files/document/se20016.pdf

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