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Revised-Medicare Fee-for-Service (FFS) Response to the Public Health Emergency on the Coronavirus (COVID-19)

Craneware® Insights Regulatory Updates – CWI1227 (20 April 2020)


Topic

Revised-Medicare Fee-for-Service (FFS) Response to the Public Health Emergency on the Coronavirus (COVID-19)

On April 10, 2020, CMS posted a revision to the MLN Matters® Special Edition Article, number SE20011, in which updates to the original MLN Matters® Article are provided.

Provider Types Affected

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

Departments/Areas Affected

Ambulance
Business Office
Compliance / Revenue Integrity
Finance
Laboratory – General
HIM/Medical Records
OP Clinics
Telemedicine

What You Need to Know

The first edition of the MLN Matters® Special Edition Article, number SE20011, was posted on March 16, 2020. For information on the original article, please refer to Craneware Insights article #CW1211. The information provided below highlights only the changes contained in the April 10, 2020 MLN Matters® article.

Billing for Professional Telehealth Distant Site Services During the Public Health Emergency (PHE) (New) CMS is expanding the telehealth benefit, on a temporary basis, in response to the COVID-19 PHE. A complete list of payable services under the telehealth benefit may be accessed via: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.

For dates of service on or after March 1, 2020, professional claims for all telehealth services are to be billed as follows:

  • Place of Service (POS): The POS should reflect what it would have been had the telehealth service been furnished in person.
  • Modifier 95: Append modifier 95 to indicate that the service furnished was performed via telehealth.
  • Modifier GQ: Use this modifier for services furnished as part of a federal telemedicine demonstration project in Alaska and Hawaii using asynchronous (store and forward) technology.
  • Modifier G0: Use this modifier when services furnished are for the diagnosis and treatment of an acute stroke.
  • Modifier GT: Critical access hospitals (CAHs) method II claims should continue to append modifier GT for services furnished via interactive audio and video telecommunication systems.
    Please note: There are no billing changes for institutional claims.

CMS has released a video in which answers are provided for common Medicare telehealth questions: https://www.youtube.com/watch?v=bdb9NKtybzo&feature=youtu.be

Families First Coronavirus Response Act (New)

The Families First Coronavirus Response Act waives cost-sharing (coinsurance and deductible amounts), under Medicare Part B, for Medicare patients receiving COVID-19 testing-related services. The services to which the waived coinsurance and deductible amounts apply are medical visits furnished between March 18, 2020 until the end of the PHE that result in an order for or the administration of a COVID-19 laboratory test. The medical visit must be related to furnishing or administering the COVID-19 test or the evaluation of an individual for the purpose of determining the need for the test. This is applicable to evaluation and management HCPCS codes 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.

The payment for the medical visit is made under the following applicable payment systems:

  • 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 dates of service on or after March 18, 2020 until the end of the PHE, outpatient providers, physicians, and suppliers who bill Medicare Part B under the above-mentioned payment systems should use the “CS” modifier on claim lines items to identify the service that is subject to the cost-sharing waiver for COVID-19. Medicare patients should not be billed for co-insurance and/or deductible amounts for the service to which the cost-sharing waiver applies.

Expanded Use of Ambulance Origin/Destination Modifiers (New)

For the duration of the COVID-19 PHE, Medicare will cover necessary emergency and non-emergency ground ambulance transportation from any point of origin to a destination that is equipped to treat the condition of the patient consistent with state and local Emergency Medical Services (EMS) protocols where the services will be furnished. On an interim basis, CMS is expanding the list of destinations that may 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.

For the complete list of ambulance origin and destination claim modifiers see the Medicare Claims Processing Manual (100-04), Chapter 15, Section 30 A: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c15.pdf

New Specimen Collection Codes for COVID-19 Testing (New)

CMS established the following HCPCS codes for specimen collection for COVID-19 testing, effective with 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
  • 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

CMS states these codes are billable by clinical diagnostic laboratories. However, the COVID-19 interim final rule states the following: “Independent laboratories must use one of these HCPCS codes when billing Medicare for the nominal specimen collection fee for COVID-19 testing for the duration of the PHE for the COVID-19 pandemic.”

The Medicare Claims Processing Manual (100-04), chapter 16, section 10.1 provides the following definition for “Independent Laboratory”: “An independent laboratory is one that is independent both of an attending or consulting physician’s office and of a hospital that meets at least the requirements to qualify as an emergency hospital as defined in §1861(e) of the Social Security Act (the Act.)…”

Beneficiary Notice Delivery Guidance in Light of COVID-19 (New)

In response to concerns related to COVID-19, CMS is providing flexibilities for the delivery of beneficiary notices in isolation, as follows:

  • A hardcopy of the notice(s) may be delivered to a beneficiary by any hospital worker who can safely enter the room where the beneficiary is located. If the individual delivering the notice is unable to provide answer(s) to questions the beneficiary may have concerning the notice(s), then the beneficiary should be provided with a contact phone number to call with questions. If a hardcopy of the notice(s) cannot be dropped off, they may be delivered to the beneficiary via email, if the beneficiary has access to email. The notice(s) should be annotated with the circumstances of the delivery, the name of the person making the delivery, and when and to where the email was sent.
  • The delivery of the notice(s) may be made via telephone or secure email to the beneficiary’s representatives who are offsite. The notice(s) should be annotated with the circumstances of the delivery, including the person delivering the notice via telephone, and the time of the call, or when and to where the email was sent.

CMS provided the following list of notices for beneficiaries receiving institutional care:

  • Important Message from Medicare (IM)_CMS-10065
  • Detailed Notices of Discharge (DND)_CMS-10066
  • Notice of Medicare Non-Coverage (NOMNC)_CMS-10123
  • Detailed Explanation of Non-Coverage (DENC)_CMS-10124
  • Medicare Outpatient Observation Notice (MOON)_CMS-10611
  • Advance Beneficiary Notice of Non-Coverage (ABN)_CMS-R-131
  • Skilled Nursing Advance Beneficiary Notice of Non-Coverage (SNFABN)_CMS-10055
  • Hospital Issued Notices of Non-Coverage (HINN)

Action Needed

Staff responsible for professional billing should be informed of the above-mentioned telehealth billing guidelines. Charge capture and billing systems should incorporate modifier 95, which signifies the service was delivered via telehealth.

Staff responsible for collecting beneficiary coinsurance and deductible amounts should be informed of the waiver of beneficiary amounts due for evaluation and management services furnished in connection with ordering, administering, or evaluating an individual for COVID-19 testing.

Hospitals that operate ambulance services need to be informed of the recently implemented expansion of the points of origins and destinations, as well as the associated revised claim modifiers.

Lastly, staff responsible for patient access and financial counseling should be made aware of the alternate delivery methods for delivering beneficiary notices related to inpatient care.

Effective Date

01 March 2020

Background

COVID-19 Blanket Waivers:

https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf

CMS Emergencies Webpage:

https://www.cms.gov/About-CMS/Agency-Information/Emergency/EPRO/Current-Emergencies/Current-Emergencies-page

COVID-19 Interim Final Rule:

https://www.federalregister.gov/documents/2020/04/06/2020-06990/medicare-and-medicaid-programs-policy-and-regulatory-revisions-in-response-to-the-covid-19-public

Reference

https://www.cms.gov/files/document/se20011.pdf

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