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Families First Coronavirus Response Act Waives Coinsurance and Deductibles for Additional COVID19 Related Services and Expanded Origins/Destinations for Ambulance Service

Craneware® Insights Regulatory Updates – CWI1222 (09 April 2020)


Topic

Families First Coronavirus Response Act Waives Coinsurance and Deductibles for Additional COVID19 Related Services and Expanded Origins/Destinations for Ambulance Service

On April 7, 2020, CMS posted a special edition article of MLN Connects® in which information is provided on Medicare beneficiary cost-sharing for COVID-19 testing- related services and a temporary expansion of the origin and destination locations for ambulance services.

Provider Types Affected

Critical Access Hospitals
Comprehensive Outpatient Rehabilitation Facility
OPPS Hospitals
Provider-Based FQHC
Provider-Based Rural Health Clinics
Physicians
Skilled Nursing Facility PPS

Departments/Areas Affected

Ambulatory Surgery
Ambulance
Business Office
Compliance / Revenue Integrity
Emergency Department
Finance
HIM/Medical Records
OP Clinics
Preventative Care Services
Urgent Care

What You Need to Know

The Families First Coronavirus Response Act waives the coinsurance and deductible amounts under Medicare Part B for COVID-19 testing-related services. This applies to evaluation and management visits furnished between March 18, 2020 and the end of the Public Health Emergency (PHE) that result in the following service:

  • An order or the administration of a COVID-19 test (U0001, U0002, or 87635);
  • Medical visit related to furnishing or administering such a test; or
  • Evaluation of an individual for determining the need for such a test.

The evaluation and management codes may be in any of the following categories:

  • Office and other outpatient services;
  • Hospital observation services;
  • Emergency department services;
  • Nursing facility services;
  • Domiciliary, rest home, or custodial care services;
  • Home services; or
  • Online digital evaluation and management services.

Cost-sharing does not apply for the above-mentioned medical visits when the payment is made to the following:

  • Hospital Outpatient Departments paid under the Outpatient Prospective Payment System;
  • Physicians and other professionals under the Physician Fee Schedule;
  • Critical Access Hospitals (CAHs);
  • Rural Health Clinics (RHCs); or
  • Federally Qualified Health Centers (FQHCs).
“CS” Modifier

For services furnished beginning March 18, 2020 through the end of the PHE, outpatient providers, physicians, other providers, and suppliers that bill Medicare Part B services under the above-mentioned payment systems should use the “CS” modifier on applicable claim lines  to identify the services for which the cost-sharing waiver for COVID-19 testing-related services applies. Do NOT bill the Medicare patients for co-insurance and/or deductible amounts for these services.

For professional or institutional claims that were previously submitted to Medicare Part B without the requisite “CS” modifier, physicians, hospitals, CAHs, RHCs and FQHCs are advised to notify their Medicare Administrative Contractor (MAC) and request to resubmit applicable claims with dates of service on or after March 18, 2020 with the “CS” modifier to get 100% payment for these services.

Expanded Use of Ambulance Origin/Destination Modifiers

During the COIVD-19 PHE, Medicare will cover medically necessary emergency and non-emergency ground ambulance transportation from any point of origin to any destination that is equipped to treat the patient consistent with state and local Emergency Medical Services (EMS) protocols where the services will be furnished. On an interim basis, the expanded list of destinations include but are not limited to:

  • Any location that is an alternative site determined to be part of a hospital, Critical Access Hospital (CAH), or Skilled Nursing Facility (SNF);
  • Community mental health centers;
  • Federally Qualified Health Centers (FQHCs);
  • Rural health clinics (RHCs);
  • Physicians’ offices;
  • Urgent care facilities;
  • Ambulatory Surgery Centers (ASCs);
  • Any location furnishing dialysis services outside of an End-Stage Renal Disease (ESRD) facility when an ESRD facility is not available; and
  • Beneficiary’s home.

CMS revised the descriptions for the origin and destination claim modifiers to reflect the new covered locations:

  • Modifier D – Community mental health center, FQHC, RHC, urgent care facility, non-provider-based ASC or freestanding emergency center, location furnishing dialysis services and not affiliated with ESRD facility;
  • Modifier E – Residential, domiciliary, custodial facility (other than 1819 facility) if the facility is the beneficiary’s home;
  • Modifier H – Alternative care site for hospital, including CAH, provider-based ASC, or freestanding emergency center;
  • Modifier N – Alternative care site for SNF;
  • Modifier P – Physician’s office; and
  • Modifier R – Beneficiary’s home.

Please refer to the Medicare Claims Processing Manual, Chapter 15, for a complete list of ambulance origin and destination claim modifiers.

This MLN Connects article also contains a link to a CMS video which provides information on billing telehealth services (please access the link to the MLN Connects article under the “Reference” section of this article).

This article also includes a link to the COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers where information can be obtained regarding  Medicare-enrolled ASCs temporarily enrolling as hospitals in order to provide hospital services to help address the urgent need to increase hospital capacity.

Action Needed

Outpatient facilities and physician office locations need to ensure that staff is informed of the above temporary regulation regarding the waiver of Medicare beneficiary coinsurance and deductible amounts specific to the service(s) mentioned above.

Hospitals and physician offices should identify claims previously submitted without the “CS” modifier that now require it. CMS has advised providers to contact their MACs and resubmit claims that were previously submitted without the “CS” modifier.

Staff responsible for billing ambulance services need to be informed of the expanded origin and destination locations and applicable modifiers for billing purposes.

Effective Date

18 March 2020

Background

Families First Coronavirus Response Act:

https://www.congress.gov/bill/116th-congress/house-bill/6201

Medicare Claims Processing Manual (100-04), Chapter 15:

https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c15.pdf

Reference

https://www.cms.gov/files/document/2020-04-07-mlnc-se.pdf

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