Among the many issues facing hospitals during this national emergency, is interpreting the sweeping changes which are impacting care delivery, documentation, coding, billing and reimbursement. In this, and subsequent special editions of the HotStone, we will provide the significant reimbursement, regulatory and revenue cycle changes, helping you continue what you do best!
TELEHEALTH
As outlined in our March 18th HotStone dedicated to telehealth, to mitigate the spread of COVID-19, CMS has temporarily relaxed the telehealth requirements. The 1135 Waiver issued March 6, 2020 eliminated the originating site requirement such that patients can remain in their homes to receive healthcare services during the COVID-19 Public Health Emergency (“PHE”). On March 30, 2020, CMS adopted an array of additional services for temporary inclusion in the list of compensable codes when care is rendered via telehealth.
The additional telehealth services are wide-ranging, impacting a variety of healthcare settings and a broader range of eligible clinicians. Where previously excluded, emergency department visits, initial hospital and discharge visits as well as initial nursing facility visits are now compensable when rendered through telehealth for the duration of the PHE. Therapy services, including physical, occupational, and speech language pathology (among other services) can also be paid via telehealth. In total, CMS has approved eighty-five (85) new telehealth-eligible services during the PHE. A complete list of all Medicare telehealth services can be found here:
https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes
CMS issued further guidance relative to billing traditional versus non-traditional telehealth services during the PHE:
“When billing professional claims for non-traditional telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE), bill with the Place of Service (POS) equal to what it would have been in the absence of a PHE, along with a modifier 95, indicating that the service rendered was actually performed via telehealth.”
Essentially, CMS is clarifying that visits rendered via telehealth during the PHE are considered the same as in-person visits and will be paid at the same rate as regular, in-person visits. Based on our query of CMS to obtain clarification for what constitutes “traditional” versus “non-traditional” services, CMS confirmed late on Friday April 3, 2020 that providers authorized under the waiver are to bill their traditional POS code, along with modifier 95.
CMS further clarified on a COVID-19 National Stakeholder Call March 31, 2020, that modifier 95 can be utilized for services billed on either the CMS-1500 or UB-04 claim forms. This modifier is to be reported for non-traditional telehealth services during the PHE, meaning they do not conform to the standard telehealth model.
All of these developments are important to follow, especially for telehealth services rendered at a provider-based clinic or hospital, as this would allow providers to continue providing valuable services via telehealth and obtain reimbursement. While the update provided by CMS on Friday was helpful, we have contacted them since the HCPCS codes utilized for hospital clinic visits are not on the telehealth list.
CMS instructs use of the following modifiers for traditional telehealth services:
GT for method II claims from critical access hospitals
G0 for diagnosis and treatment of an acute stroke
GQ for the federal telemedicine demonstration project in Alaska and Hawaii using asynchronous (store and forward) technology
Finally, it is important to note that services designated explicitly as telehealth services may be provided to Medicare beneficiaries via telephone only if the phone allows for both audio and video interaction between the provider and the patient. Use of “Smart Phones” is permitted predicated the device supports the two-way, real-time interaction. CMS has further allowed that services rendered via telephone audio only are also now available for payment during this emergency utilizing CPT codes 98966-98968; 99441-99443.
CREDENTIALING & SUPERVISION
CMS is temporarily allowing hospitals and healthcare systems to increase workforce capacity by allowing physicians, nurses and clinicians that are qualified and licensed, to provide care while awaiting completion of federal paperwork requirements.
While beneficial to hospitals and healthcare systems during anticipated surges, it is important that the services rendered are appropriately documented and the associated professional charges are captured and held until the practitioners are credentialed and claims can be forwarded to the applicable payer.
Dramatic expansion of virtual services is far-reaching, also including flexibilities impacting supervision of clinical staff. Supervision requirements can be satisfied “virtually” during the PHE for services requiring direct supervision by a physician or other practitioner.
CRNA
CMS has waived the physician supervision requirements that have been a long-standing Medicare requirement for CRNA billing. While this measure seeks to free up physicians and expand capacity, monitoring the guidance issued by CMS after the COVID-19 emergency will be essential to ensuring compliance.
VENTILATOR COVERAGE
Medicare is temporarily eliminating previous coverage requirements for respiratory related devices, such as ventilators. Ensuring the coding department is aware of the relaxed restriction will enable claims to be appropriately coded to the applicable MS-DRG.
ICD-10 DIAGNOSIS CODING
Due to the March 13, 2020 declaration of a national emergency for the COVID-19 outbreak, the CDC announced the new diagnosis code U07.1; COVID-19 is effective April 1, 2020. The CDC announced that the off-cycle update was unprecedented and was an exception to the code set updating process established under HIPAA because of the PHE.
It is important to note that U07.1 is only to be appended when there is explicit documentation to support confirmation of, or presumptive positive test result for COVID-19. A presumptive positive test result means the individual has tested positive for the virus at a local or state level, but has not yet been confirmed by the CDC. If the provider documents “suspected”, “possible”, “probable” or “inconclusive” COVID-19, the provider should not assign code U07.1 The CDC recommends hospitals hold inpatient and outpatient claims until the confirmation of COVID-19 has been obtained so as to append the proper diagnosis code. The potential MS-DRG’s for U07.1 are 177, 178, 179, 791, 793, 974, 975 and 976.
It is essential to utilize the ICD-10 COVID-19 diagnosis codes, when applicable, to ensure the hospital receives the newly implemented 20% increase in DRG payments for COVID-19 patients.
NEW SPECIMEN COLLECTION CODES
On March 31st, CMS released two new HCPCS codes to identify and reimburse specimen collection specific to COVID-19. The following HCPCS are effective with line item dates of service on or after March 1, 2020:
G2023 – Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), any specimen source.
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 (“SNF”) or by a laboratory on behalf of a home health agency (“HHA”), any specimen source.
In keeping with standard billing practices, these HCPCS codes should be used when there is a cost incurred for the collection of the specimen.
We will be issuing additional COVID-19 HotStone’s this week, regarding coding, Clinical Documentation Improvement and Cost Reporting. If you have any questions, please contact Vonda Moon, Senior Principal at vondamoon@sunstoneconsulting.com.