REVISION – Medicare Fee-for-Service (FFS) Response to the Public Health Emergency on the Coronavirus (COVID-19)
Craneware® Insights Regulatory Updates – CWI1215 (25 March 2020)
Topic
REVISION – Medicare Fee-for-Service (FFS) Response to the Public Health Emergency on the Coronavirus (COVID-19)
On March 20, 2020, CMS released a revised MLN Matters® Special Edition Article, number SE20011, in which information is provided regarding blanket waivers issued under a declared public health emergency (PHE) that affect Medicare Fee-for-Service (FFS) providers.
Provider Types Affected
Critical Access Hospitals
OPPS Hospitals
Provider-Based FQHC
Provider-Based Rural Health Clinics
Physicians
Departments/Areas Affected
Business Office
Compliance / Revenue Integrity
Electrophysiology Lab
Finance
HIM/Medical Records
Telemedicine
What You Need to Know
On March 16, 2020, CMS released MLN Matters® Special Edition Article, number SE20011, in which information is provided regarding blanket waivers issued under a declared public health emergency (PHE) that affect Medicare Fee-for-Service (FFS providers. Please access Craneware Insights article #1211 for a summary of information contained in SE20011.
CMS has revised this article on multiple dates. The original article was revised on March 18, 2020 to add a section on telehealth services. The revision states that Medicare will pay for office, hospital, and other visits furnished via telehealth across the country and including in a patient’s residence starting March 6, 2020. The range of personnel that may offer telehealth services include providers such as doctors, nurse practitioners, clinical psychologists, and licensed clinical social workers.
There are three types of virtual services that may be provided to Medicare beneficiaries:
- Medicare telehealth visits;
- Virtual check-ins; and
- e-visits.
Medicare provided the following table to summarize telemedicine services:
|
Type of Service |
Description of Service |
HCPCS/CPT® Code |
Patient Relationship with Provider |
|
Medicare Telehealth Visits |
A visit with a provider that uses telecommunication systems between a provider and a patient. |
Common telehealth services include:
For a complete list: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes |
For new* or established patients. *To the extent the 1135 waiver requires an established relationship, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency. |
|
Virtual Check-in |
A brief (5-10 minutes) check in with your practitioner via telephone or other telecommunications device to decide whether an office visit or other service is needed. A remote evaluation of recorded video and/or images submitted by an established patient. |
|
For established patients |
|
E-Visits |
A communication between a patient and their provider through an online patient portal |
|
For established patients |
Please note that the above information on telehealth services was also provided in a CMS news article in which they announced the “expansion” of telehealth as well as issuing a “Telemedicine Health Care Fact Sheet” and a “Medicare Telehealth Frequently Asked Questions (FAQs)” document. We are providing the links to these documents under the “Background” section of this article. Craneware also published an Insights article, #1212, entitled “COVID-19 – Telehealth Expansion”.
The March 20, 2020 revision to SE20011 partially rescinds the previously issued directive concerning the “DR” condition code and the “CR” modifier, which are to be used for claims to receive Medicare payment based on a “formal waiver” under Section 1135 of the Social Security Act. The revised article explicitly states that the “DR” condition code and the “CR” modifier are NOT required for telehealth claims for which Medicare payment is based on a “formal waiver”. However, Medicare reminds providers that there are three scenarios in which modifiers are required for Medicare telehealth services:
- GQ modifier: Required when telehealth services are furnished via asynchronous (store and forward) technology as part of a federal telemedicine demonstration project in Alaska and Hawaii;
- GT modifier: Required when telehealth services are billed under Critical Access Hospital (CAH) Method II; and
- G0 modifier: Required when telehealth services are furnished for the purpose of diagnosis and treatment of an acute stroke.
Action Needed
Facilities and providers should read the revised MLN Matters article and the associated telehealth documents in their entirety. Inform staff responsible for billing telehealth services that the previously issued directive on the “DR” condition code and the “CR” modifier do NOT apply to telehealth services.
Effective Date
01 March 2020
Background
Telemedicine Health Care Fact Sheet:
https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet
Medicare Telehealth Frequently Asked Questions (FAQs), March 17, 2020:
https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf
Section 1135 of the Social Security Act:
Reference
https://www.cms.gov/files/document/se20011.pdf
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