FREE TELEHEALTH WEBINAR WITH 1 CEU FROM AAPC, amba & PMRNC

We  taught another LIVE webinar on Telehealth-Telemedicine & Telemonitoring and we recorded it.  You can download the webinar, along with the pdf file and the quiz download page here.

https://donself.sharefile.com/d-s659d84c5e9c4cb1a

There IS a reason to watch this one as there were some MASSIVE CHANGES that occured in this one due to the April 30th updates from CMS for providers, PTs, RHCS, Hospitals and everyone else that we went over in this webinar.  I hope it helps and feel free to share this with others to help them optimize their income and keep them out of trouble.   

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!"

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

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.    

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.

1. 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) 

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.

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

If you're been waiting on CMS to treat RHCs and FQHCs properly regarding telehealth - the wait is over.   The MLN that came out April 30  was huge (you can download it at the bottom of this page) and they are paying these clinics per the MLN.     

During the COVID-19 PHE, RHCs and FQHCs can furnish any telehealth service that is approved as a Medicare telehealth service under the PFS.   Did you know there are 244 of them and you can download them at the bottom of this page?

In addition, effective March 1, 2020, these services include CPT codes 99441, 99442, and 99443, which are audio-only telephone evaluation and management (E/M) services. RHCs and FQHCs can furnish and bill for these services using HCPCS code G2025. To bill for these services, at least 5 minutes of telephone E/M service by a physician or other qualified health care professional who may report E/M services must be provided to an established patient, parent, or guardian. 

For telehealth distant site services furnished between January 27, 2020, and June 30, 2020, RHCs and FQHCs must put Modifier “95” (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) on the claim. RHCs will be paid at their all-inclusive rate (AIR), and FQHCs will be paid based on the FQHC Prospective Payment System (PPS) rate.  

They go into detail on the MLN about the reporting as well as what happens to the payment rates after July 1st and the new code they will want used then (G2025).  

They raised the amounts they are paying for the G0071 from $13.53 to $24.76, dating back to March 1st.

•Paying for Portal Services 99421-99423 – but rolled into the G0071with the 7-day combined time at $24.76

•No CR Modifier Required Mar 1 – end of PHE

•MACs will automatically reprocess any claims with G0071 for services furnished on or after March 1, 2020 that were paid before the claims processing system was updated. 

Block 42        Rev Code      052X

Block 43        Estab OV

Block 44        G2025CG95

Block 45       January 27 through June 30

Block 46       1 unit

Block 47       $100

You will be paid your AIR and then the claim will be reprocessed in July 2020 for total payment of $92

Starting July 1st, you will continue using G2025 with no modifiers

Check out the MLN at the bottom of the page