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Is CMS now allowing hospitals to bill for professional telehealth services directly on a hospital UB04 claim?

On May 27, 2020, CMS published an update to their FAQ document entitled “COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing” which we have linked below. One of the updates to the document included the addition of a new contents section entitled “FF. Outpatient Therapy Services”. In the first Q&A added under this new heading CMS seems to imply that hospitals are now able to bill for “outpatient therapy services” rendered via telehealth technology on hospital 12X or 13X claim types, so long as the telehealth therapy service is not included as part of a bundled institutional payment. Per CMS, these outpatient therapy hospital telehealth services would be reported in conjunction with modifier 95 on the corresponding hospital claim.

We would caution that this change in policy has not been addressed by CMS in any transmittal, special edition bulletin, interim final rule, or any other document released as of today’s date (June 4, 2020). Therefore, we are unable to provide any additional interpretation beyond what is noted in the FAQ document. We have sent an email to CMS to clarify the following questions surrounding this change in policy and will provide an update as soon as a response is received or additional clarifying guidance is published.

In our email to CMS we asked for clarity on the following questions:

  1. To what date is this policy change retro-actively effective to?
  2. Which specific CPT and/or HCPCs codes does CMS consider “outpatient therapy services”?
  3. Are there any other UB04 claim requirements outside of the use of modifier 95 for these hospital telehealth services?
  4. When should hospitals utilize this new telehealth billing flexibility vs the previously outlined provider-based department expansion concept detailed in the CMS interim final rule CMS-5531-IFC? (for a summary of the PBD expansion policy please see click here)

CMS COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing,