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It has been a confusing and chaotic time for healthcare providers.  On 5/1 CMS again made changes to their directives for telehealth.  Among providers affected by these changes are RHC providers, professional services and providers who have been using telephone only codes and outpatient hospital based clinics.  They have also clarified the use of Modifier CS.  CMS stated they now realize a large population of Medicare beneficiaries do not have access to asynchronous communication (real time audio/video) and to assist beneficiaries and providers there are now additional codes that allow telephone only interaction. 

CMS added telephone only codes to list of telehealth services

  • There are now 89 telephone only codes

Changes for RHCS

Now through 6/30/2020

  • Providers are now able to receive reimbursement for telephone only E/M codes by billing G2025 with CG and 95 modifier
  • They will be paid the AIR rate through this time time

After 7/1/2020

  • CMS will reconcile payments made in the amount of the AIR rate.
    • If you AIR rate was less than $92 they will remit additional funds
    • If your AIR rate was more than $92 CMS will recoup the overpayment
  • No longer submit CG modifier, only submit 95 modifier

CS Modifier Clarification

  • 5/5/2020 CMS Covid-19 Office Hours Call clarified the following:
  • CS modifier is used when related to testing services
  • A test must be ordered or administered on the date of service receiving CS modifier
  • Outpatient only claims
  • Cannot be applied for receiving diagnosis only of COVID but must have test ordered or performed on the date of service applied
  • Applies to E/M coding only

G0463 – Facility Charges

  • E/M and G0463 cannot be billed together during COVID-19
    • Q3014 may be billed in place of G0463 when an E/M is also billed.
    • No E/M billed you may bill G0463


Betsy Rios, CPC

Written by Betsy Rios, CPC

Healthcare Coding & Consulting Services

(a.k.a. HCCS)

This blog is an extension of our uncompromising values and dedication to our clients, staff, and the HIM industry as a whole.


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