Medical Reimbursement Consultants since 1988, serving tens of thousands of physicians
MODIFIER CS FOR COVID TESTING RELATED
OLD MODIFIER - NEW PURPOSE
CMS has repurposed an old modifier that we've used in different circumstances before. This time, it is to be used for COVID-19 testing related visits or services during the PHE. If your medical provider is ordering or administering or even evaluating an individual for the purpose of determining whether the test should be ordered, use CS modifier, IF A TEST WAS ORDERED! On April 16 in the CMS Office Hours call, CMS dropped a bombshell on folks and said - "only use the CS modifier if the test was ordered or is ordered. If no test was ordered don't use the CS modifier". On the 17th - half of the call was about that with people arguing - and CMS said "we will get new guidance on that. The call on Apr 21 repeated "we still do not have new guidance so follow the current rule that a test is required before using CS". The call today (ended 5 minutes ago) on April 23 - "no change and no new guidance"
This prompts Medicare to pay 100% of the service instead of their normal 80% and it also means you will not be collecting anything from the patient for described outpatient E&M services that have the CS modifier.
This modifier is now active dating back to March 18 and will be used to the end of the PHE.
For professional claims, physicians and practitioners who did not initially submit claims with the CS modifier must notify their Medicare Administrative Contractor (MAC) and request to resubmit applicable claims with dates of service on or after 3/18/2020 with the CS modifier to get 100% payment .For institutional claims, providers, including hospitals, CAHs, RHCs, and FQHCs, who did not initially submit claims with the CS modifier must resubmit applicable claims submitted on or after 3/18/2020, with the CS modifier to visit lines to get 100% payment. CMS has repeatedly said "not for inpatient E&M codes!"
CODES FOR ANTIBODY TEST
EFFECTIVE APRIL 10, 2020
Immunology
Revised 86318
New Code 86328
New Code 86769
86318: Immunoassay for infectious agent antibody(ies), qualitative or semiquantitative, single step method (eg, reagent strip);
86328: severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19])
(For severe acute respiratory syndrome coronavirus 2 [SARS-CoV-2] [Coronavirus disease {COVID-19}] antibody testing using multiple-step method, use 86769)
86769: Antibody; severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19])
(For severe acute respiratory syndrome coronavirus 2 [SARS-CoV-2] [Coronavirus
USE E&M CODES FOR TELEHEALTH
CODE WHERE YOU NORMALLY SEE PATIENTS!
Let's start with Medicare Part B. There have been some that have said that you can bill Medicare Part B for E&M codes when the patient does not have access to an audio-video type communication.
THAT IS FALSE - when we are discussing MEDICARE Part B.
(It is true with some Part C Advantage plans that we'll discuss later). Medicare requires the audio-video live interactive communication between the provider (not the nurse or MA) in order to bill the office visit codes for telehealth. If anyone tells you differently today (it may change in the future), slap the snot out of them and remind them that the CMP is $11,000 for false claims per claim - AND THEN let them listen to this recording from CMS made April 7 and published by CMS: https://www.cms.gov/fi…/audio/covid19officehours04072020.mp3
EXAMPLES:
OFFICE BASED FAMILY PHYSICIAN, NP OR PA – DOES NOT GO TO HOSPITAL, NURSING HOME OR PATIENT HOMES….
* USE POS 11 – BILL OFFICE VISIT CODES 99201-99215 WITH MODIFIER 95 ON
* EVERY TELEHEALTH PERFORMED WITH PATIENTS VIA AUDIO-VIDEO
* REGARDLESS WHERE THE PATIENT IS
* REGARDLESS WHERE THE PROVIDER IS
OFFICE BASED INTERNAL MEDICINE – DOES OFFICE, HOSPITAL & NURSING HOME, DOES NOT GO TO PATIENT HOMES: (Audio-Video visits only)
* USE POS WHERE PATIENT IS – WITH APPROPRIATE E&M VISIT FOR THAT LOCATION.
* POS 11 – OV CODES FOR PTS AT HOME WITH 95 MODIFIER
* POS 21 – HOSPITAL CODES FOR PTS AT HOSPITAL WITH 95 MODIFIER
* POS 31 – SNF CODES FOR PTS IN SNF WITH 95 MODIFIER
HOME VISIT PHYSICIAN, NP OR PA (audio-video visits only)
* USE POS 12 – BILL HOME VISIT CODES 99341-99349 WITH MODIFIER 95 ON
EVERY TELEHEALTH PERFORMED WITH PATIENTS VIA AUDIO-VIDEO
use modifier 95
DEFINITELY FOR MEDICARE PART B
Yes - Medicare Part B has said that modifier 95 means it was done via a synchronous (audio-video live) means, so use 95 with Part B Medicare. Obviously, if you did a phone call only (99441-99443), you would not need the 95 modifier as the phone call is not via audio-video. On a call with CMS on April 9, CMS said "for all services during the phe we are asking providers to use 95 modifier". They had just been discussing what modifier to use with the Office Visit codes, but that is a direct quote. No - I do not believe you should use the modifier CR or DR with Medicare Part B claims.
I also do NOT recommend you use place of service 02 with Part B claims, although I am told that some commercial carriers like you to use 02.
You should also use it with other commercial companies that tell you to.
USE WHAT THE PAYER TELLS YOU TO USE.
If Prudential says to bill all telehealth with modifier MB for MA Bell, if you want to get paid by Pru - you will follow their rules. If Aetna says use modifier TT telehealth calls made on Tuesday - then do it if you want Aetna's money. Follow the rules the payer gives you.
COVID SPECIMEN COLLECTION & TESTS
SPECIFIC TO LOCATION - MAY 1 UPDATED
EFFECTIVE March 31, we have 2 new HCPC codes for specimen collection for LABS only
G2023 Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), any specimen source (About $23.46 Medicare payment)
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
BUT WHAT ABOUT PHYSICIAN OFFICES?
IN the upcoming federal register (which you can download at the bottom of this page called April 30 - 5531), CMS said they recognize that physician offices are going through a lot of expense in obtaining samples for tests and Congress did not authorize them to pay non labs for G2023, so they are giving you permission to use 99211 for those. ON page 188, they say: "
Therefore, for the duration of the PHE, we will recognize physician and NPP use of CPT code 99211 for all patients, not just patients with whom they have an CMS-5531-IFC 188 established relationship, to bill for a COVID-19 symptom and exposure assessment and specimen collection provided by clinical staff incident to their services.
For the duration of the COVID-19 PHE, we are therefore finalizing on an interim basis that when the services described by CPT code 99211 for a level 1 E/M visit are furnished for the purpose of a COVID-19 assessment and specimen collection, the code can be billed for both new and established patients. "
Note that both codes say "any source" so don't restrict these only to the nasal swabs. These are only for trained personnel and not for patients to do their own tests.
- Question: Are there Healthcare Common Procedure Coding System (HCPCS) and Current Procedural Terminology (CPT) codes available for COVID-19 laboratory testing?
Answer: Yes, CMS has created two HCPCS codes in response to the urgent need to bill for these services. The codes are:
- U0001, CDC 2019-nCoV Real-Time RT-PCR Diagnostic Panel and
- U0002, 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19), any technique,
multiple types or subtypes (includes all targets), non-CDC.
Additionally, the American Medical Association (AMA) Current Procedural Terminology (CPT) Editorial Panel has created CPT code 87635 (Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique)
- U0001, CDC 2019-nCoV Real-Time RT-PCR Diagnostic Panel and
rpm or telemonitoring with don
HELPING PATIENTS STAY OUT OF THE HOSPITAL
Wow - our telemonitoring service has taken off and we are adding on new clients constantly and helping practices and patients. Between that and our Chronic Care Management program - we are helping keep patients OUT OF THE HOSPITAL and helping practices increase income at the same time! If you want information on these, reach out to us or just click on my schedule link here to have a one-on-one appointment with Don. This is not for webinars as this is a consultation with Don individually: DON'S CONSULTATION SCHEDULER
You do not have to spend tens of thousands of dollars and buy monitors with our system. It is on a month to month rental basis and most of our clients start with 10 or 20 monitors, give those to patients and then let us know how many more they want and we help them. Your profit margin per patient ranges from $56 a month to $75 per month on an average basis and the work can be performed by your staff instead of the doctor. This helps keep patients out of the hospital and out of the ER - which saves the payer (Medicare) a lot of money, helps the patient and improves patient care for your clinic. We have clients who have been using our service for the past 15 months who love it - so talk to us. You can also visit WWW.TELECARE-USA.COM
BE CAREFUL - AUDITS ARE HAPPENING
IT'S NOT A GOOD IDEA TO CHEAT
There are many people giving FALSE information that will get you into trouble if you follow their advice. The ONLY audit that CMS and Medicare is not going to investigate for services performed during this PHE emergency is whether the patient getting a telehealth call or visit is new or established to your practice. They WILL be auditing whether the service was done via audio-video or whether the patient requested the phone call or not. CMS, OIG and DOJ have CMPs (Civil Money Penalties) of $11,000 to $22,000 per claim - so do the math folks.... it is not worth it to commit fraud. If you do plan on committing fraud in your billing, then you better erase your browser history as the fact you KNOW it is fraud will be found out and that makes it criminal on top of civil.
DOCTOR TREATING THROUGH THE DOOR or talking to caregiver
PATIENT QUARANTINED - DOC IN THE HALL
One question that pops up often is "the patient is quarantined and the doc is out the hospital room door treating the patient. How do we bill? That question was asked April 7th in a CMS phone conference. CMS said "both the doctor and the patient is in the same place of service, so it will not be telehealth - but there is no reason that the doctor cannot bill a normal hospital visit as if they were in the same room.
Remember, a non telehealth subsequent visit code only requires 2 of 3 and it's not difficult to document the history and medical decision making.
The question also arises about one doctor in their own office talking to another doctor or nurse or family member wherever the patient is and billing that as telehealth (audio-video) or telemedicine (audio only) The April 1st update where CMS said “include direct interactions between practitioners and caregivers” when discussing the telehealth visits pretty well leaves that one open for billing, in our opinion.
OUTDATED INFORMATION
USE CURRENT DATA - IF YOUR DATA IS BEFORE APRIL 30... OUTDATED
if the data you are using is more than 36 hours old - it is probably OUTDATED. Yes, changes are happening constantly. Since April 1st, I have had to update a webinar I taught on that day a total of 7 times... so far. Do not go by any coding advice regarding telehealth or telemedicine that you received a couple of weeks ago as it's not current.
For instance, if you're using the AMA guide published at first of April - it's outdated. If you are using data that says to use POS 02 on everything - it's outdated. If you're using modifier CR - it's outdated. Check on this page often - as we're updating it daily
doctor or np or pa working from home
CALLING PATIENTS FROM HOME
Folks have asked "but my doc or NP or PA is quarantined at home for 2 weeks - what place of service do we use?" CMS has repeatedly said to use the same place of service the doc or NP or PA would be using if we did not have the crisis unless your provider plans to permanently do calls from home (permanently means forever - even after the COVID crisis). Make it easy on yourself and use 11 for office if that is where the provider would be if all was still the way it was before COVID became a household word. Use the normal address you would use in block 34 for these as well.
TELEHEALTH - TELEMEDICINE - TELEMONITORING
By the way - none of this applies to facility billing. I know NOTHING about facility billing and I cannot even spell UB04!
COMMERCIAL INSURANCE COMPANIES
Each carrier can make up their own rules - and they are - and many are changing their rules as quickly as Medicare Part B has. You need to check with each carrier.UHC published on the 6th that they were allowing E&M visit codes to be used for audio/video or for audio ONLY on commercial claims, Medicare UHC Advantage and others. That is different than Part B. You can download the UHC update at the UHC website (updated April 8) at https://www.uhcprovider.com/en/resource-library/news/Novel-Coronavirus-COVID-19/covid19-telehealth-services/covid19-telehealth-services-telehealth.html where they also talk about their policy on waiving the copays or coinsurance in their policy so read it.
CIGNA has their own policy also that was published at: https://static.cigna.com/COVIDYou need to visit each carrier's website that you deal with and don't just look at it - screen save it or download it and save it so that if later the carrier audits you - you have the proof of what their policy was.You also want to update the data on a regular basis to protect yourself.
AETNA - UPDATED 5/1
ARKANSAS BCBS
Blue Cross Blue Shield of Massachusetts has processed 180,000 telehealth claims since changing its policy to both expand coverage for telephone and virtual visits and reimburse them at the same rate as in-person visits during the COVID-19 state of emergency. The March telehealth claims figure is a 3600% increase over February and a 5100% increase over the monthly average for 2019.
Blue Cross and Blue Shield of Illinois
Blue Cross and Blue Shield of Illinois is temporarily lifting cost sharing payments for medically necessary health services delivered through telehealth. This applies to all fully insured members whose benefit plan included telehealth benefits. Blue Cross and Blue Shield of Illinois has also added 18 additional telehealth procedure codes that health care providers may use when billing Blue Cross and Blue Shield of Illinois for medically necessary health care services, including codes for behavioral health therapy.
Blue Cross Blue Shield of Michigan
Blue Cross Blue Shield of Michigan will waive prior authorizations for diagnostic tests and covered services for COVID-19, cover those tests at no cost share to members, waive prescription refill limits on maintenance medications, and expand access to telehealth and nurse/provider hotlines. This applies to fully insured and Medicare Advantage plan members. Blue Cross Blue Shield of Michigan will also work to support self-insured customers who choose to take similar actions.
Tricare Drops Telehealth Copays, Adds Phone Call Coverage in Emergency Measure
Check out AHIP for all of the carriers:
https://www.ahip.org/health-insurance-providers-respond-to-coronavirus-covid-19/
PORTAL CODES
- Question: What is an online patient portal?
Answer: An online patient portal is a secure online website that gives patients 24-hour
access to personal health information from anywhere with an Internet connection by
using a secure username and password.
- THE following codes are for fee for service and also for RHCs and FQHCs (as of 4/9) for the duration of the PHE.
- 99421 - Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes
- 99422 - Online digital evaluation and management service, for an established
patient, for up to 7 days, cumulative time during the 7 days; 11-20 minutes
- 99423 - Online digital evaluation and management service, for an established
patient, for up to 7 days, cumulative time during the 7 days; 21 or more minutes.
G2061 Qualified non-physician healthcare professional online assessment, for an established patient, for up to seven days, cumulative time during the 7 days; 5-10 minutes $12.27
G2062 Qualified non-physician healthcare professional online assessment service, for an established patient, for up to seven days, cumulative time during the 7 days; 11-20 minutes $21.65
G2063 Qualified non-physician qualified healthcare professional assessment service, for an established patient, for up to seven days, cumulative time during the 7 days; 21 or more minutes $33.92
G2012 Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion $14.80 - AGAIN - WHY USE IT???
SUPERVISION RELAXED
Through this interim final rule, CMS is altering supervision requirements for physicians and other practitioners. For the duration of the PHE for the COVID-19 pandemic, CMS is altering the definition of direct supervision at § 410.32(b)(3)(ii), to provide that the necessary presence of the physician or other practitioner for direct supervision includes virtual presence through audio/video real-time communications technology when use of such technology is indicated to reduce exposure risks for the beneficiary or health care provider. This is found at: https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf which is also below in the downloads area.
out of state doctors
Practitioner Locations
CMS is temporarily waiving requirements that out-of-state practitioners be licensed in the state where they are providing services when they are licensed in another state. CMS will waive the physician or non-physician practitioner licensing requirements when the following four conditions are met: 1) must be enrolled as such in the Medicare program; 2) must possess a valid license to practice in the state which relates to his or her Medicare enrollment; 3) is furnishing services – whether in person or via telehealth – in a state in which the emergency is occurring in order to contribute to relief efforts in his or her professional capacity; and, 4) is not affirmatively excluded from practice in the state or any other state that is part of the 1135 emergency area.
• In addition to the statutory limitations that apply to 1135-based licensure waivers, an 1135 waiver, when granted by CMS, does not have the effect of waiving state or local licensure requirements or any requirement specified by the state or a local government as a condition for waiving its licensure requirements. Those requirements would continue to apply unless waived by the state. Therefore, in order for the physician or non-physician practitioner to avail him- or herself of the 1135 waiver under the conditions described above, the state also would have to waive its licensure requirements, either individually or categorically, for the type of practice for which the physician or non-physician practitioner is licensed in his or her home state.
This can be found at: https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf
