COVID-19 FAQs on Medicare Fee-for-Service Billing Updated Again

Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare

This 140-page COVID-19 FAQ document was updated on July 28, 2020.  

This is what’s new in this version during July:

  • Page 10 – Diagnostic Laboratory Services14. Question: If a physician/non-physician practitioner (NPP) reports CPT code 99211 “Office or other outpatient visit for the evaluation and management of an established patient that may not require the presence of a physician”, for assessment and collection of COVID-19 diagnostic laboratory test specimen for a new patient as permitted under Medicare during the COVID-19 PHE, and the physician/Non-physician practitioner (NPP) subsequently, on a different day, furnishes an Evaluation and Management (E/M) visit to the patient for other reasons, can he/she report a new patient E/M visit code for the subsequent visit?  Also, 15. Question: Can physicians/NPPs apply the Cost Sharing (CS) modifier to claims for pre-surgery examination services that include COVID-19 testing?
  • Page 21 & 22 – Hospital Services22. Question: Can hospitals bill for and receive separate payment for COVID-19 testing services that are provided in the outpatient department prior to an inpatient admission?
  • Pages 69 & 70 – Medicare Telehealth27. Question: How should the CS modifier, which removes application of beneficiary cost sharing (deductible and co-payment), be applied to telehealth services and/or E/M visits?
  • Page 74 – Medicare Telehealth43. Question: Which healthcare professionals can furnish and bill for diabetes self management training (DSMT) services they furnish via telehealth?  Also, 44. Question: Can DSMT services provided by hospitals be billed as telehealth services?
  • Page 75 – Physician Services45. Question: Can Medicare pay for telehealth services furnished by physicians or practitioners who are physically located outside of the United States?
  • Page 96 – ACO28. Question: What claim types and facility types is CMS using to identify an inpatient service for treatment of COVID-19 to identify episodes of care for use in adjusting Shared Savings Program calculations?
  • Page 97 – ACO 29. Question: When excluding from Shared Savings Program calculations Parts A and B FFS payment amounts for an episode of care for treatment of COVID-19, will COVID-19 admissions/stays in a Skilled Nursing Facility (SNF) trigger these episodes of care? Also, 30. Question: Will the episode span the beginning of the month in which the admission date occurs through the end of the month following the month in which the discharge date occurs?
  • Page 98 – ACO31. Question: For a claim to be used to identify an episode of care for treatment of COVID-19 according to 42 CFR § 425.611, do International Classification of Diseases, Tenth Revision, Clinical Modification (ICD-10-CM) codes B97.29 “Other coronavirus as the cause of diseases classified elsewhere” (for discharges occurring on or after January 27, 2020, and on or before March 31, 2020) or U07.1 “COVID-19” (for discharges occurring on or after April 1, 2020, through the duration of the COVID-19 PHE period) need to be the principal diagnosis on the claim?  Also, 32. Question: Are current procedural terminology (CPT) codes for administration of health risk assessment (96160 and 96161), outpatient visit for the evaluation and management for new (99201–99205) and established patients (99211–99215), transitional care management services (99495 and 99496), and advanced care planning (99497 and 99498) included in the definition of primary care services in 42 CFR § 425.400 and used for purposes of Medicare fee-for-service beneficiary assignment in the Medicare Shared Savings Program, when delivered via telehealth services?
  • Pages 98 & 99 – Cost Reporting1. Question: Will CMS delay the filing deadline for cost reports impacted during the COVID-19 PHE?
  • Pages 126 & 127 – Hospital Billing for Remote Services1. Question: Is there a tool that can help hospitals better understand flexibilities during the COVID-19 PHE when the beneficiary’s home is serving as a provider-based department of the hospital (that is, where the hospital ensures the location meets all of the conditions of participation, to the extent not waived, and registers the beneficiary as a hospital outpatient)?   Also, 2. Question: Can hospitals and other institutional providers bill for telehealth services that are furnished by certain practitioners?  And 3. Question: For services furnished to patients in a provider-based department of the hospital (which may include the patient’s home during the COVID-19 PHE), when can a hospital bill for the clinic visit code (G0463, “Hospital outpatient clinic visit”) and when can a hospital bill for the originating site facility fee (Q3014)?
  • Pages 128 & 129 – Hospital Billing for Remote Services4. Question: When a physician is employed by a hospital and typically furnishes services in the hospital, but furnishes services to a registered hospital outpatient from the physician’s home during the COVID-19 public health emergency, can the hospital bill G0463 as they usually would for a clinic visit furnished in the hospital outpatient setting? And 5. Question: When there is no Medicare-enrolled professional billing for a telehealth service, can the hospital furnish services remotely?
  • Pages 131 & 132 – Outpatient Therapy Services4. Question: Is there a graphic that can show me how to bill for outpatient therapy services furnished via telehealth during the COVID-19 Public Health Emergency? And 2. Question: How do hospitals bill for outpatient therapy services furnished by employed or contracted therapists using telecommunications technology on the UB-04 claim form during the COVID-19 PHE?
  • Page 133 – Outpatient Therapy Services5. Question: In the scenario in which the hospital chooses to bill for telehealth services of an employed/contracted PT, OT, or SLP using a -95 modifier on each applicable service line on a UB-04 for a registered outpatient, can the hospital also bill for the originating site facility fee (Q3104)?

If you haven’t done so already, I encourage you to bookmark this FAQ website and share it with your bookkeepers/billers as well.  It provides a lot of answers to billing questions related to the PHE.