Topic: Revision vs. Appeals- Telehealth Place of Service 02
Billing for Medicare Telehealth Services
The Centers for Medicare & Medicaid Services (CMS) and the Department of Health and Human Services (HHS) have supplied recent waivers that would influence how telehealth services and paid for and delivered by Federal Government payers. With the newly given out Section 1135 waivers, Medicare telehealth services are to be billed as if the service had been given out in person. The claim is to consider the designated Place of Service (POS) code 02, which is telehealth, to show the billed service was done as a professional telehealth service from another site.
Billing and coding
As explained by Noridian, when invoicing professional claims for telehealth services with service dates of March 1, 2020, and beyond, during the public health emergency an individual should bill with the place of service (POS) without the public health emergency, together with a modifier 95, showing that the service provided was done through telehealth. This is a different guideline from the previous ones to bill with a place of service of 02. Therefore, claims invoiced with POS of 02 will be paid at a facility rate.
Noridian also advised that professional service claims that were already presented with a POS of 02 can be rectified through the Noridian Medicare self-service portal. This will, therefore, permit providers to make changes on omissions or clerical errors, without resubmitting or requesting for an appeal. CMS, however, does not require CR modifier on telehealth services. Consistency with the current regulations for old telehealth services, there are two instances where modifiers can be used on Medicare telehealth professional claims: in a federal telemedicine demonstration project by using store and forward technology, the GQ modifier, and in the diagnosis and treatment of acute stroke cases, the GO modifier. It is always crucial to check on the modifier to use.
Place of service
A POS code list has been published by Centers of Medicare & Medicaid Services for the practitioner to tell the insurer through the billing form where the patient and provider were during the health encounter. For the synchronous telehealth service in Medicare, a POS 02 must be reflected in the bill. The Place of Service used when services are not simultaneous is the place of the encounter that the service is done. It, therefore, has effects on what address is reflected in the billing form.
POS codes and modifier -95 on physicians
The Interim Final Rule finalizes the payment policy to permit physicians to get paid at a non-facility rate for the Medicare telehealth services. Medicare is to pay the non-facility telehealth service amount when billed with the place of service, such as POS 11, which is office. Therefore, physicians should attach modifier -95 to claim lines that are delivered through telehealth. POS 02 claims will be paid at a standard facility rate, usually less than a non-facility rate using the Medicare fee schedule.