New CMS Telehealth Rule: Speed Cashflow, Update Billing

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New CMS Telehealth Rule: Speed Cashflow, Update Billing

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Just when you thought you got your head semi-wrapped around Medicare telemedicine rules, they go and throw it out the window! On March 30, CMS issued an Interim Final Rule and released new guidance on how to code and bill for rapidly evolving telehealth services.

Before you file another claim, here are the three sweeping changes you must implement now. Taking the time to apply these new telehealth billing rules now means you’ll receive claims payment faster – and face fewer denied claims in the future.  

Apply Telehealth Modifier 95 to All Claims

There has been a lot of confusion over what modifier to use when submitting claims for telehealth services with an E/M code such as 99201-99215 (Office visits). The March 31, 2020 COVID-19 National Stakeholder Call provided one uniform method.

Now you’ll use modifier 95 on ALL Medicare telehealth claims – professional and facility, clarified CMS Administrator Seema Verma. Modifier 95 indicates the office visit was performed via telehealth – and gets the claim to process around Medicare’s historic system edits.  

Eliminate Telehealth Claim Denial Trigger With Usual Place of Service

If you’ve been confronted with a wave of telehealth denials, the new CMS Place of Service guidelines should hopefully eliminate this frustration.

Effective immediately, you should no longer apply a Place of Service (POS) of 02 to indicate telehealth. Instead, you should use the intended originating site of where you would have provided the service outside of COVID-19.

Example: If you would have seen the patient in the office with place of service (POS 11), then that’s the POS you report now.

Modifier 95 with POS 11 indicates the office visit was performed via telehealth. It also allows the service to be paid at 100%. Using a POS of 02 subjects the code to a facility reduction of 15%.  

Digital Visits Now Allowed for New Patients Too

The new telehealth rule changes also change which patients you can bill for virtual check-ins. Codes G2010 and G2012 (digital communication services) were previously restricted to established patients only. They now are applicable to new patients, too.  

Stay Up to Date

HPCA is tracking changes to telehealth and other COVID-19 topics. Updates will be posted on the recently launched COVID-19 Action Center website.

The COVID-19 Action Center hosts a variety of how-to articles, tools and online training sessions to help you ethically optimize the reimbursement you receive during these challenging times.

The next related training “Coronavirus: Get Paid for Private Pay Non-Face-to-Face Patient Care” is being presented by coding expert, Kim Garner Huey, MJ, CHC, CPC, CCS-P, PCS, CPCO, on April 8th, and will be covering private payer telemedicine reimbursement

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Meet Your Writer

Jen Godreau CPC, CPMA, CPEDC, COPC Content Director

Jennifer Godreau, CPC, CPMA, CPEDC, COPC, has almost 20 years of experience in billing, coding, compliance, and practice management. She develops the content and programs for Healthcare Training Leader, a practice-specific online training company offering step-by-step advice on increasing reimbursement and avoiding compliance violations. Prior to joining Healthcare Training Leader, Jennifer supervised the program delivery for EMRs, practice management systems and compliance and revenue cycle services for more than 6,000 providers. Thousands of software products - encoders, claims management, auditing, and HIPAA compliance, have been created with her teams and helped thousands of practices more easily reduce revenue losses and comply with complex regulations. Her passion for breaking down healthcare rules and requirements in simple steps has provided practical advice, education, and risk reduction strategies to numerous associations, payers and medical specialties especially in primary care, otolaryngology, eye care, and pediatrics. Jennifer’s advocacy resulted in supervision rule revisions, new CPT codes, and CMS compliance contracts. She oversaw the provider auditing and education for one of the major corporate integrity health system settlements. Jennifer has authored and presented on numerous healthcare compliance and payment challenges. Her education guides include the Certified Otolaryngology Coder (CENTC) exam study guide and the AAPC Professional Medical Coding Curriculum. Jennifer has a Bachelor of Arts from Wittenberg University in Springfield, Ohio. She holds certificates in coding, auditing, pediatric coding, and ophthalmology billing and coding, and is AAPC Vice President of the Naples, FL chapter. Please reach out to Jennifer for step-by-step guidance at