Current Updates


Latest updates from CMS regarding Telehealth

CMS gives flexibility to teaching hospitals to meet the deadline of July 1 for submission of Medicare GME affiliation agreements to October 1, 2020.

CMS clarified Hospital Outpatient Services Furnished in Temporary Expansion Locations in patient’s home and how it can be billed.

  • If they are registered as an outpatient of the hospital and the hospital makes the patient’s home provider-based to the hospital as a temporary expansion site, should the hospital bill use telehealth modifier 95?
  • In this situation the hospital is furnishing outpatient hospital service, not a telehealth service to a patient in a temporarily relocated department of the hospital as discussed at 85 FR 27560.

RHCs can perform mental health visits as a distant site telehealth service.

RHCs can also furnish a medical visit and a mental health visit on the same day furnished as a distant site telehealth service.

  • Report G2025 for both services 0900 for mental health and 052X for medical visit. See SE20016 for billing guidance.

Virtual Supervisory presence allowed in RHCs during PHE.

RHCs cannot bill for specimen collection it is included in the AIR.


To view the updated FAQ follow this link:


As of April 30th, CMS has announced…


  • Under new waivers and rule changes, Medicare will no longer require an order form the treating physician or other practitioner for beneficiaries to get COVID-19 tests.
  • Pharmacists can work with a physician or other practitioner to provide assessment and specimen collection services, and the physician or other practitioner can bill Medicare for the services.  Pharmacists also can perform certain COVID-19 tests if they are enrolled in Medicare as a laboratory, in accordance with a pharmacist’s scope of practice and state law.
  • CMS will pay hospitals and practitioners to assess beneficiaries and collect laboratory samples for COVID-19 testing and make separate payment when that is the only service the patient receives.  This builds on the previous action to pay laboratories for technicians to collect samples for COVID-19 testing from homebound beneficiaries and those in certain non-hospital settings, and encourages broader testing by hospitals and physician practices.
  • CMS will allow certain provider-based hospital outpatient departments that relocate off-campus to obtain a temporary exception and be paid under PPS and will not be paid at lower rates under the Physician Fee Schedule as they normally would.
  • Long term acute care hospitals can now accept any acute-care hospital patients and will be paid at a higher Medicare payment rate, as mandated by the CARES Act.
  • Nurse practitioners, clinical nurse specialists, and physician assistants can now provide home health services.
    1. They can now order home health services
    2. Establish and periodically review a plan of care for home health patient and certify and recertify that patient is eligible for home health services.  This applies to Medicare and Medicaid.
  • CMS will not reduce Medicare payments for teaching hospitals that shift their residents to other hospitals to meet COVID-related needs, or penalize hospitals without teaching programs that accept these residents.  This allos teaching hospitals to lend available medical staff to support other hospitals.
  • PT and OT may delegate maintenance services to physical and occupational therapy assistants in the outpatient settings.
  • CMS has waived the periodic review of staff privileges during COVID-19 emergency declaration.
  • CMS is allowing payment for certain partial hospitalization services for individual psychotherapy, patient education and group psychotherapy that are delivered in temporary expansion locations, including patients’ homes.
  • Temporarily allowing community mental health centers to offer partial hospitalization and other mental health services to clients in the safety of their homes.
  • CMS will not enforce certain clinical criteria in LCDs that limit access to therapeutic continuous glucose monitors for beneficiaries with diabetes.


Telehealth Specific:

During PHE, CMS is waiving limitations on the types of clinical practitioners that can furnish Medicare Telehealth services. Hospitals may bill for services furnished remotely by hospital-based practitioners to Medicare patients registered as hospital outpatients, including when a patient is at home and the home is serving as a temporary provider based department of the hospital. Including counseling and educational service as well as therapy services.
  • Hospitals may bill as the originating site for telehealth services furnished by hospital-based practitioners to Medicare patients registered as outpatients, including when the patient is located at home.
  • Audio only telephone services has been broadened to include many behavioral health and patient education services.  CMS is also increasing payments for these telephone visits to match payments for these services from a range of about $14-$41 to about $46-$110.  Payments are retroactive to March 1, 2020.
  • Since some Medicare beneficiaries don’t have access to interactive audio-video technology that is required for Medicare Telehealth services, or choose not to use it even if offered by their practitioner. CMS is waiving the video requirement for certain telephone evaluation and management services, and adding them to the list of Telehealth services.


RHC Specific Updates

They have now rescinded their initial instruction for RHCs to bill whatever Telehealth code by definition (asynchronous real time video/audio only) they provided with 95 modifier for payment of G2025 (this code was to be effective 7/1/20).
  • Now RHCs need to bill G2025 with CG modifier for services rendered between 1/27/2020 and 6/30/2020 for any E/M Audio only services (99441,99442 and 99443)
  • After 7/1/2020 no CG modifier required.
  • CMS is waiving requirements which required RHCs and FQHCs be independently considered for Medicare approval if services are furnished in more than one permanent location.


Stark Law Revision

Now allows hospitals and other health care providers can pay above or below fair market value for the personal services of a physician (or an immediate member of a physician’s family) and parties may pay below fair market value to rent equipment or purchase items of services.
  • Health care providers can support each other financially to ensure continuity of health care services
  • Hospitals can provide benefits to their medical staffs, such as meals, laundry service or child care services while physicians are at the hospital and engaging in activities that benefit the hospital and its patients.
  • Health care providers may offer certain items and services that are solely related to COVID-19 purposes, even when the provision would exceed the annual non-monetary compensation cap.
  • Physician owned hospitals can temporarily increase the number of their licensed beds, operating rooms and procedures rooms.
  • Any physician in a group may order medically necessary DHS (Designated Health Services) that is furnished to a patient by one of the group’s technicians or nurses in the patient’s home contemporaneously with a physician service that is furnished via Telehealth by the physician who ordered the DHS.
  • Group practices can furnish medically necessary MRIs, CT scans or clinical laboratory services from locations like mobile vans in parking lots that the group practice rents on a part-time basis. 



CS Modifier Updates 

Recovered Revenue Opportunity – Cost Sharing Waiver 


What does this mean? 

  • CMS has waived cost-sharing under Medicare Part B (coinsurance and deductible amounts) for Medicare patients for COVID-10 related testing services backdating to 3/18/2020 by entering the CS modifier on applicable claims. 
  • There are several scenarios, but essentially MCR pays 80/20% (80 being the MCR portion) and 20% going to a secondary or covered by the patient out of pocket. 
  • The 20% is the opportunity for your facility to recoup revenue.
  • If billed to the patient in the current economy (without the Cost Sharing waiver applied), it will most likely end in collections or write-offs.  
  • If billed to the secondary, and they happened to pay (without the Cost Sharing waiver applied), there is a high probability that the secondary will take back any monies paid to the facility.  

How can HCCS Help? 

  • If these claims are not reviewed, money is being left on the table!
  • Your facility should be able to identify all claims with patients tested or worked-up for COVID-19 (excluding Inpatient encounters) from 3/18/2020up to now (and through the end of the PHE).  
  • This might be achieved by pulling a report where COVID-19 test codes were applied: U0001, U0002, or 87635 
  • Provide HCCS with this list of accounts, and we will review, add the CS modifier, and request a rebill for any encounters where applicable 

Who does this impact?  

  • Hospital Outpatient Departments paid under Outpatient Prospective Payment System 
  • Physicians and professionals under the Physician Fee Schedule
  • Critical Access Hospitals (CAHs) 
  • Rural Health Clinics (RHCs) 
  • Federally Qualified Health Centers (FQHCs) 

What chart types will this apply to? 

  • OP
  • ER
  • OBS
  • Pro Fee
  • Pro Clinic

Professional Claims  

For professional claims, physicians and practitioners who did not initially submit claims with the CS modifier must notify their Medicare Administrative Contractor (MAC) and request to resubmit applicable claims with dates of service on or after 3/18/2020 with the CS modifier to get 100% payment.  

Institutional Claims 

For institutional claims, providers, including hospitals, CAHs, RHCs, and FQHCs, who did not initially submit claims with the CS modifier must resubmit applicable claims submitted on or after 3/18/2020, with the CS modifier to visit lines to get 100% payment.   


  • Information included is based on updates from CMS as of 4/16/2020 and are subject to change 
  • Review state-specific Medicaid and third-party insurance plans to determine whether services are covered, and which codes are recognized. 
  1. Centers for Medicare & Medicaid Services (CMS):
  2. Centers for Medicare & Medicaid Services (CMS) MLN Connects Newsletter, dated 4/7/2020: 

RHC Regulatory Updates for Telehealth – New Payment 4/17/2020


What has changed?

  • New payment for Telehealth Services available to RHCs/FQHCs
  • new code (G2025) will be added on 7/1/2020 and it will pay $92 as a distant site telehealth provider for RHCs and FQHCs
    • In order to bill this G code, telehealth services must be provided via Synchronous Telemedicine Services (real-time interactive audio and video telecommunications system)
    • If not utilizing Synchronous Telemedicine Services (audio-only), continue to bill G0071

What about Telehealth Visits for patients seen prior to 7/1/2020?

  • RHCs/FQHCs that use interactive real time audio/video platforms can bill for telehealth services backdating to DOS 1/27/2020 up through 6/30/20 with a 95 modifier (E/Ms, etc.) 
    • Modifier 95 should be appended to any applicable telehealth codes, E/Ms for your RHC from 1/27/2020-6/30/2020
    • Any telehealth claims with 95 modifier will signify that you are requesting reimbursement for G2025
  • Audio-only services will still be billed as G0071 through and after 7/1/20 (Virtual check-ins, etc.)

What about payment rates?

  • RHCs utilizing the 95 modifier on qualifying telehealth claims will receive their normal AIR rate of until 7/1/2020
    • After 7/1/2020 - CMS will either recoup or pay the difference between the $92 and your facility’s AIR Rate
    • Providers need to be aware of the RHC’s normal AIR rates to ensure the takeback doesn’t cause financial problems when it occurs
Example Scenarios for Payment Recoup or Reimbursement:
    • Your RHC’s normal AIR Rate is $100. You bill 200 claims with **G2025 from 1/27/2020-6/30/2020. CMS will take back $1,600 in July
    • Your RHC’s normal AIR Rate is $80. You bill 200 claims with **G2025 from 1/27/2020-6/30/2020. CMS will pay you an additional $2,400 in July.
    • **G2025 – between 1/27/2020-6/30/2020 this will actually be coded with any of the applicable telehealth codes with the appropriate 95 modifier succeeding that code

What is HCCS doing & how can we further help your RHC?

  • HCCS will be applying G2025 on all qualifying telehealth claims for DOS 7/1/2020 and forward
  • HCCS will be appending the 95 modifier on all qualifying telehealth claims from DOS 4/20/2020-6/30/2020
    • Please note that the 95 modifier can be applied backdating through 1/27/2020
  • HCCS can absolutely review all telehealth claims coded between 1/27/2020-4/19/2020 to append the 95 modifier
  • Please reach out for a consultation if this is something you would like for HCCS to assist with for your RHC!



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