Still questioning when to use Modifier CS? There is still time to receive appropriate reimbursement.
Pursuant to the Families First Coronavirus Response Act implemented in March of 2020 by the Centers for Medicare and Medicaid Services (“CMS”), cost-sharing (coinsurance and deductibles) is waived for COVID-19 testing-related services, to include evaluation and management (“E/M”) medical visits as follows:
Visits resulting in an order for, or the administration of, a COVID-19 test.
Visits that are related to furnishing, or administering, such a test, or
Visits for the evaluation of an individual for the purposes of determining the need for such a test.
As a result, outpatient providers, physicians, or other providers and suppliers billing under Medicare Part B will be paid at one hundred percent (“100%”) of the applicable Medicare rate. Essentially, the CS modifier waives the patients coinsurance/deductibles and serves as an attestation that your service qualifies for one hundred percent (“100%”) reimbursement.
If there was an oversight in your original claim submission, you can contact your Medicare Administrative Contractor (“MAC”) to obtain approval to resubmit claims with the modifier CS. Of note, in these instances Medicare patients should NOT have been charged any co-insurance and/or deductible amounts for these services.
You may be asking, does this apply to me? The answer is yes, it applies to you if you are a:
Hospital outpatient department paid under the Outpatient Prospective Payment System (“OPPS”)
Physician and other qualified non-physician practitioner paid under the Medicare Physician Fee Schedule (“MPFS”)
Critical Access Hospital (“CAH”)
Rural Health Clinic (“RHC”)
Federally Qualified Health Center (“FQHC”)
Should the CS modifier be appended to the COVID-19 test itself and/or all services that result in such a test?
The answer is “no”. Cost-sharing does not apply to laboratory tests paid under the Clinical Lab Fee Schedule (“CLFS”). Appending CS will not result in increased reimbursement for the test. Additionally, CMS has provided an updated list of applicable E/M service CPT codes that are appropriate for use with the CS modifier. The link to this list can be found at:
https://www.cms.gov/files/zip/cs-modifier-hcpcs-codes-physicians-non-physician-pactitioners.zip
Need help assessing your compliance with CS modifier regulations and reimbursement?
SunStone offers services specifically geared toward analysis of proper claim submissions and resubmissions, ensuring compliance with regulatory guidance with maximum revenue capture. If you have any questions, please contact Vonda Moon, Senior Principal at vondamoon@sunstoneconsulting.com or Joli Fitzgibbons, Director at jolifitzgibbons@sunstoneconsulting.com.