Billing Through the Pandemic
Updated: Jan 7, 2022
Our previous post covered everything that's been going on with telehealth throughout the pandemic, touched on some of their billing requirements, and outlined how regulations change during Public Health Emergencies (PHEs).
This article is going to give a deeper, more comprehensive look at what billing requirements shifted during the PHE so you have the knowledge you need to make sure your organization is billing correctly.
HHS already extended the PHE emergency declaration through January 2022, but with new strains of COVID developing, it is possible this date will be extended further. The uncertainty around this situation makes it imperative these guidelines are heeded to avoid additional claim denials.
As a reminder from our previous post, once a President officially declares a state of emergency and the HHS Secretary declares a public emergency, the 1135 Waiver allows flexibility to waive or modify certain healthcare regulations. The 1135 waiver is what allows for many of the billing changes this article will discuss, as derived from the CMS Medical Learning Network document se20011.
POS 02 and POS 10:
One of the upcoming changes is the revision of the POS 02 code and implementation of the new POS 10 that will take effect on January 1, 2022. Prior to this change, POS 02 simply indicates that a telehealth service was provided, but with payers changing reimbursement levels after the public health emergency (PHE) ends, updates to the codes were needed.
Starting January 1, POS 02 will indicate that the patient was not in their home when receiving their health-related services through telecommunication.
The new POS 10 will indicate that the patient *was* in their home when they received their services through telecommunication.
"CR" and "DR":
During the PHE, "CR" (catastrophe/disaster) modifier and "DR" (disaster related) condition codes are also required to indicate when services are being performed under the authority of the 1135.
For example, the waiver allows acute care hospitals with excluded inpatient rehabilitation units to move inpatients from those units to an acute care bed, which would require the "DR" condition code.
Additionally, when replacement prescription fills of covered Medicare Part B drugs are lost or unusable due to the PHE, that would require a "CR" modifier. A full list of other examples are available on the CMS MLN page.
This modifier remains unchanged and should continue to be used for telehealth scenarios in addition to 2 other special modifier scenarios:
G0 Modifier: Telehealth services provided for diagnosis and treatment of acute stroke.
GQ Modifier: Telehealth services provided as part of federal demonstration project in Alaska and Hawaii using asynchronous technology.
The GE modifier indicates that a service was performed by a resident without the presence of a teaching physician under the received expansion of allowed codes during the PHE as well For example: 99204-99205, 99214-99215, 99495-99496, 99421-99423, 99453, 99441-99443, and HCPCS codes G2010 and G2012 can be billed with the GE modifier throughout the PHE.
Originally used in 2010 to indicate services for the Gulf of Mexico oil spill, a CS modifier now indicates visits related to testing for COVID-19 where cost sharing does not apply. The CS modifier should be applied to procedure categories such as office and outpatient, hospital observation, emergency department, and nursing facilities. A full list of codes is available from CMS.
Ambulance Destination and Origin Modifiers:
During the PHE, Medicare covers medically necessary group ambulance transportation from any point of origin to a destination that is equipped to treat the patient's condition. With this update, a variety of modifiers have been updated to account for the new covered locations. Full Medicare ambulance billing details are available here, and I've included a number of examples below for quick reference:
Modifier D - CMHC, FQHC, RHC, urgent care facility, non-provider-based ASC or freestanding emergency center, location providing dialysis services and not affiliated with ESRD facility
Modifier E – Residential, domiciliary, custodial facility (other than 1819 facility) if the facility is the patient’s home Modifier H - Alternative care site for hospital, including CAH, provider-based ASC, or freestanding emergency center
Modifier N - Alternative care site for SNF
Modifier P - Physician’s office
Modifier R - Patient’s home
Two new Level II HCPCS codes are now effective throughout the PHE to account for COVID-19-related specimen collection:
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 SNF or by a laboratory on behalf of a home health agency, any specimen source
If your organization has experienced issues with billing during this PHE, it’s essential to ensure that any existing issues leading to denials are addressed immediately and effectively to prevent further lost revenue. To learn more about how we can reduce your claim denials through root cause determination with machine learning, read more about our process and how CARMA, our Claims and ReMittance Analysis system, works to help get you paid what you deserve on your claims.