Regulatory changes related to COVID-19 are flying at a fast pace these days and some of the most recent changes affect how you should code for telehealth services and COVID-19 testing when billing Medicare.
Provisions within the Families First Coronavirus Response Act (FFCRA) and the Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency Interim Final Rule affect Medicare Part B payment during the COVID-19 Public Health Emergency.
Modifier -CS. The FFCRA waives cost-sharing for COVID-19 testing-related services for Medicare Part B patients. Cost-sharing is waived for office visits that result in the order or administration of the COVID-19 test, or the evaluation of an individual to determine the need for such a test. The cost-sharing waiver is effective for dates of service starting March 18, 2020, until the end of the public health emergency.
Physicians should use the -CS modifier on applicable claims to identify the service subject to the cost-sharing waiver. Medicare beneficiaries should not be charged for any coinsurance or deductible for those services. The -CS modifier will signal the Medicare Administrative Contractors (MACs) to pay 100% of the allowable cost for the service. Physicians should contact their MACs and request to resubmit applicable claims with dates of service on or after March 18, 2020, that were submitted without the -CS modifier. The -CS modifier should not be used for services unrelated to COVID-19.
POS codes and modifier -95. The Interim Final Rule updates payment policies to allow physicians to be paid at the non-facility rate for Medicare telehealth services. During the COVID-19 crisis, Medicare will pay the non-facility amount for telehealth services when they are billed with the place of service (POS) the physician would have used if the service had been provided in person (e.g., POS 11 – Office). Physicians should append modifier -95 to the claim lines delivered via telehealth. Claims with POS 02 – Telehealth will be paid at the normal facility rate, which is typically less than the non-facility rate under the Medicare physician fee schedule.
Additional information on billing for telehealth services is available on the American Academy of Family Physicians’ (AAFP) COVID-19: Telehealth Tools page.
The following table provides a summary of the POS and modifier requirements for Medicare Part B.
|Service||Place of Service||Modifier(s)|
|Office visit related to COVID-19 testing||11 – Office||-CS|
|Telehealth visit related to COVID-19 testing||11 – Office||-95, -CS|
|Office visit not related to COVID-19||11 – Office||None|
|Telehealth visit not related to COVID-19||11 – Office||-95|
|Virtual Check-In (HCPCS G2012, G2010)||11 – Office||None|
|E-Visit (CPT 99421-99423)||11 – Office||None|
|Telephone Evaluation and Management (CPT 99441-99443)||11 – Office||None|
Commercial payers are generally following Medicare’s lead in terms of coverage and policy. However, coding guidance varies from payer to payer. The AAFP is tracking payer policies closely. A table of private payer policies and list of frequently asked questions are available on the Academy’s COVID-19: Practice Management Page.
One final note: Appropriate diagnosis coding can help further distinguish services related to COVID-19. The Centers for Disease Control and Prevention has updated the ICD-10-CM official coding and reporting guidelines to address COVID-19 diagnosis and exposure coding.
— Erin Solis, Manager, Practice & Payment at the AAFP
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