Updates for Medicare Fee For Service (FFS): CMS MLN Matters Special Edition Article

fee for service

The Centers for Medicare & Medicaid Services (CMS) has updated Special Edition (SE) MLN Matters® article SE20011 Medicare Fee for Service response to address the changes made for the issuance of additional guidelines and waivers regarding the 2019 Novel Coronavirus, COVID-19 (CMS, 2020). This MLN Matters® Special Edition Article is for providers and suppliers who bill Medicare Fee For-Service (FFS). This includes blanket waivers for providers and suppliers, a CMS telehealth video regarding coverage of services, guidance on Beneficiary Notice Delivery, and expansion of Ambulance origins and destination modifiers.

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CMS Guidelines for Telehealth Coding & Billing During PHE

CMS guidelines for telehealth

The Centers for Medicare & Medicaid Services (CMS) has decided to update the CMS billing and coding guidelines for telehealth or in-home provider services due to the urgency of the current 2019-Novel Coronavirus (COVID-19) pandemic (CMS, 2020). CMS has broadened the scope for reimbursement for virtual check-ins and other digital communications with patients to safely and effectively respond to this Public Health Emergency (PHE). In the interim, telehealth services will not be limited by program restrictions put in place by Medicare (Federal Register, 2020). Evaluation and management (E/M) service codes cover these remote and communication technology-based services performed by a physician or non-physician practitioner (NPP).

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Medicare Telehealth Services Now Included In Expanded Payment Protocol

medicare telehealth services

The Centers for Medicare & Medicaid Services (CMS) has decided Medicare will expand its payment protocol for professional Medicare telehealth services provided to beneficiaries in all areas of the country, in all settings. “Telehealth, telemedicine, and related terms generally refer to the exchange of medical information from one site to another through electronic communication to improve a patient’s health” (CMS, 2020). Due to the current Public Health Emergency (PHE) declared for 2019 Novel Coronavirus (COVID-19), this expansion was considered a necessary step to assist in healthcare reimbursement and only designed to last as long as this emergency

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Medicare Telemedicine Coding & Reimbursement Guidelines for COVID-19

telemedicine reimbursement guidelines

CMS released the Medicare telemedicine coding and reimbursement guidelines for healthcare providers to use during the COVID-19 pandemic (CMS, 2020). According to the CMS Medicare Telemedicine Health Care Provider Fact Sheet, reimbursement for these visits are considered the same as in-person visits and are paid at the same rate (CMS, 2020). The U.S. Department of Health & Human Services Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs (CMS, 2020).

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Telehealth in COVID-19 Times: Virtual Services, Telemedicine Providers & HIPAA

telemedicine providers

There are 3 main types of virtual health services physicians and other professionals can provide to Medicare beneficiaries: Medicare Telehealth Visits, Virtual Check-Ins, and E-Visits (CMS, 2020). Providers such as doctors, nurse practitioners, clinical psychologists, and licensed clinical social workers, will be able to offer telehealth to their patients. See more on coding for telemedicine in response to the 1135 Waiver Authority and Coronavirus Preparedness and Response Supplemental Appropriations Act, in our previous article here.

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CMS Increases List of Payable Medicare Telemedicine Services

Telemedicine

Adapting to the influx of telehealth services in response to the COVID-19 outbreak, CMS has adjusted the “List of services payable under the Medicare Physician Fee Schedule when furnished via telehealth” in order to provide as much support and care as possible (2020). In addition, CMS issued updated criteria for risk adjustment of Medicare telemedicine services, as well as guidelines on how to bill for telemedicine.

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CMS Clarifies Risk Adjustment Criteria for Coding Telehealth Services

Coding Telehealth

CMS clarified on April 10, 2020, that the submission of ICD-10-CM diagnoses codes for Risk Adjustment are permitted from coding telehealth services as long as it meets the set criteria (i.e. inpatient, outpatient, or professional service and from a face-to-face encounter) (CMS, 2020). CMS is stating that telehealth services can meet the face-to-face requirement “when the services are provided using an interactive audio and video telecommunications system that permits real-time interactive communication” (2020). From a medical coding and billing standpoint, the change in the telehealth services criteria for risk adjustment is causing updates to how these services are billed.

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The Importance of Specificity in Documentation and Coding HCCs

HCC specificity

As a follow-up to our previous articles on the subject of Risk Adjustment and HCCs, we now review some scenarios of HCC chronic conditions and the importance of specificity in documentation and coding. Accurate and complete documentation of chronic condition diagnoses by clinicians is an essential component of the risk adjustment and the HCC process. It is also imperative that the documentation of a disease/condition be as specific as possible. Specificity can make a difference in the patient’s treatment plans, as well as accurate code assignments, which then leads to appropriate HCC assignment and payment.

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Updates Coming to the Quality Payment Program in 2020

Quality Payment Program

In the 2020 Medicare Physician Fee Schedule Final Rule released by the Centers for Medicare and Medicaid Services late last year, several changes were made to the value-based Quality Payment Program (QPP) to simplify the rules for providers. These updates will “impact more than 1 million clinicians eligible for one or both of the QPP’s two performance tracks, the Merit-based Incentive Payment System (MIPS) and the Advanced Alternative Payment Models (APMs). CMS estimates that 880,000 clinicians will be MIPS-eligible in 2020, and between 210,000 and 270,000 clinicians will achieve Qualifying APM Participant (QP) status in 2020.”

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