Note: This post was updated on 4/16/20 to reflect the most current information.
During this COVID-19 pandemic, we have received several questions on how facilities should be billing for telehealth services. As we continue to collect as much information as possible, we wanted to provide our findings so far:
- Currently, billing for Medicare telehealth services is limited to professionals only
- Hospitals are only eligible to bill for the originating site facility fee using HCPCS code Q3014
- There are no changes for reporting modifier GT on Telehealth services billed under critical access hospital (CAH) method II
- Managed care departments should check with their commercial payers for additional guidance on payment for telehealth services, as it could differ from Medicare’s regulations
- Use Place of Service (POS) code equal to what it would have been had the service been furnished in-person
- CMS provides a list of HCPCS codes, normally furnished in-person, that are payable under the Medicare Physician Fee Schedule when provided via telehealth. The complete list of HCPCS codes can be found here: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes
- Medicare pays providers the same amount for telehealth services as it would if the service was provided in person
- For telehealth with a site of service payment differential (i.e. services paid different rates in the office versus the facility) Medicare pays the facility payment rate
- For claims with dates of service on or after 3/1/20, report modifier 95 to indicate a service was provided via Telehealth.
- CMS is not requiring modifier CR (catastrophe/disaster related) on telehealth services. To comply with current rules, however, the following modifiers should still be reported as usual:
- GQ – required on claims furnished in Alaska or Hawaii for asynchronous (store and forward) technology
- G0 – reported for services to diagnose and treat acute strokes
- March 6th, 2020 – Section 1135 waiver temporarily waives certain restrictions on Medicare telehealth coverage under the Coronavirus Preparedness and Response Supplemental Appropriations Act
- Medicare beneficiaries can now receive expanded healthcare services, regardless if their symptoms are related to COVID-19, in the safety of their home
- Previously, Medicare could only pay practitioners for routine telehealth services furnished to beneficiaries in a medical facility in rural or health professional shortage areas
- Allows physicians, nurse practitioners, physician assistants, clinical psychologists, and licensed clinical social workers, among others, to provide telehealth services within their scope of practice
- Beneficiaries can now receive telehealth services in a variety of settings, in addition to their home, such as: physician offices, hospitals, nursing homes, or rural health clinics
- Providers must use an interactive audio and video telecommunication system that permits real-time communication between the provider at the distant site and the patient at the originating site
- Penalties for HIPAA violations during the COVID-19 emergency will be waived against health care providers serving patients, in good faith, through everyday communication technology like FaceTime or Skype
As changes to telehealth services continues to evolve, we will provide any additional guidance as we learn more.
To talk to one of our consultants about what this might mean for your hospital, give us a call at 888.779.5663.