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If we make a patient’s home a temporary expansion site of our provider-based department (PBD), are we required to only append modifiers PO or PN to items and services that are reimbursed under the Outpatient Prospective Payment System (OPPS) or do these modifiers need to be appended to all claim line items?

Per the CMS Claims Processing Manual Chapter 4, modifier PN is required to be appended to all items and services furnished at non-excepted provider-based departments even if the modifier does not affect reimbursement for the specific CPT or HCPCS code. This includes items and services that are reimbursed under distinct fee schedules; for example, drugs, diagnostic laboratory tests, therapy services, etc. CMS has not waived or changed the reporting requirements for modifier PN in light of the COVID-19. Therefore, if a non-excepted PBD relocates (including relocation to the patient’s home), modifier PN would still need to be appended to all items and services furnished at the non-excepted temporary location regardless of impact to payment.

Although not explicitly noted in the Claims Processing Manual, we believe the same logic would hold true for modifier PO if the hospital relocates an excepted PBD to the patient’s home – assuming the hospital applies for and is granted an extraordinary circumstances exemption by their CMS Regional Office.

Although not explicitly noted in the Claims Processing Manual, we believe the same logic would hold true for modifier PO if the hospital relocates an excepted PBD to the patient’s home – assuming the hospital applies for and is granted an extraordinary circumstances exemption by their CMS Regional Office.

On their bi-weekly Office Hours calls, CMS clarified that modifiers PO or PN (based on the relocated PBDs excepted or non-excepted status) should be appended to telehealth originating site facility fee, Q3014, when this service is rendered in a temporary expansion site of a hospital PBD (including the patient’s home). On the call, the CMS representatives stated that as reimbursement for Q3014 is set by statute (and not through OPPS or PFS rule making) modifiers PO and PN will not affect the facility reimbursement rate for Q3014, however, the modifiers will still be required to indicate the service was provided in a temporary expansion site of a hospital PBD.

For a comprehensive overview of the updated CMS guidelines related to temporary expansion sites of hospital provider-based departments, please see our Craneware summary document linked below:

https://public.craneware.com/assets/public/documents/Hospital-Billing-Guidelines_05062020.pdf

CMS Claims Processing Manual Chapter 4 Section 20.6.12 “Use of HCPCS Modifier PN”:

https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c04.pdf