New Payment Updates for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) During the COVID-19 Public Health Emergency (PHE)

By Baker Newman Noyes April 28, 2020

Updated May 20, 2020: On April 17, 2020, the Centers for Medicare and Medicaid Services (CMS) provided an update related to the Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) requirements and payments.  Flexibilities noted are in effect during the COVID-19 Public Health Emergency (PHE) for services provided to Medicare beneficiaries.

Telehealth services

Specific to Distant Site Providers:

• Health care practitioners working for a RHC or FQHC are authorized to furnish distant site telehealth services, so long as services provided are within their scope practice.
• On April 30, 2020, CMS expanded the list of qualifying telehealth services and waived the video requirement for certain telephone evaluation and management services. Medicare beneficiaries will be able to use audio-only telephones to receive approximately 89 different types of services.  (Updated 05/20/2020)
  • A list of approved telehealth services is available at https://www.cms.gov/files/zip/covid-19-telehealth-services-phe.zip
• Practitioners may furnish telehealth services from any location (including their home) during the time that they are working for the RHC or FQHC
• For telehealth services provided between January 27 and June 30, 2020, RHCs and FQHCs should use the appropriate CPT/HCPCS code with modifier “95” (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) on the claim.
  • RHCs will be paid at their all-inclusive rate (AIR); FQHCs will be paid based on the FQHC Prospective Payment System (PPS) rate
  • Claims will be automatically reprocessed in July when the Medicare claims processing system is updated with the new payment rate
  • RHCs and FQHCs do not need to resubmit these claims for the payment adjustment
• Effective July 1, 2020 through the end of the COVID-19 PHE, RHCs and FQHCs should use G2025 to identify services furnished via telehealth
  • Claims will be paid at a rate of $92
  • Modifier 95 is not required
• G2025 should be billed with revenue code 052x or 0780

Collection of co-insurance

• For services related to COVID-19 testing, including telehealth, RHCs and FQHCs must waive the collection of co-insurance from beneficiaries
  • Coinsurance should not be collected from beneficiaries if waived
• For services in which the coinsurance is waived, include the “CS” modifier on the service line
  • Claims with the “CS” modifier will be paid with the coinsurance applied, and the Medicare Administrative Contractor (MAC) will automatically reprocess these claims beginning on July 1, 2020

Virtual communication services

• Online digital evaluation and management (E&M) services are non-face-to-face, patient-initiated, digital communications using a secure patient portal
  • Typically, a brief discussion over the phone to determine if a face-to-face is required
  • An online digital evaluation and management service using a patient portal, that requires a clinical decision
• May be furnished to both new and established patients
• G0071 is billable when the discussion requires the skill level of a practitioner (physician, NP, PA, CNM, CP or CSW)
• Virtual communication services are non-billable. Does not include discussions that could be conducted by a nurse, health educator, or other personnel
• Claims with HCPCS code G0071 may be submitted alone or with other payable services
• To receive payment, RHCs and FQHCs should report services with HCPCS code G0071 (Virtual Communication Services) during the PHE
  • Online digital evaluation and management codes billable using HCPCS code G0071 include:
    • CPT code 99421 (5-10 minutes over a 7-day period)
    • CPT code 99422 (11-20 minutes over a 7-day period)
    • CPT code 99423 (21 minutes or more over a 7-day period)
  • Virtual communication services billable using HCPCS code G0071 include:
    • HCPCS code G2012
    • HCPCS code G2010
• Claims submitted with HCPCS code G0071 on or after March 1, 2020, and for the duration of the PHE, will be paid at the new rate of $24.76. Note that MACs will automatically reprocess any claims with G0071 for services furnished on or after March 1, 2020 that were paid before the claims processing system was updated
• G0071 should be billed with revenue code 0521
• Telephone-only services reported using CPT codes 99441-99443 are not included on the qualifying visit list for RHCs or FQHCs. RHCs and FQHCs have not been authorized to bill Medicare for these services

Consent to treat

• Beneficiary consent is required for all services, including non-face-to-face services
• The consent may be obtained at the same time the services are initially furnished
• The consent may be obtained by someone working under general supervision of the RHC or FQHC practitioner, and direct supervision is not required to obtain consent
• Additional information is available here.

Cost reporting

Costs for furnishing distant site telehealth services will not be used to determine the RHC AIR or the FQHC PPS rates, but must be reported on the appropriate cost report form.

• RHCs must report both originating and distant site telehealth costs on Form CMS-222-17, line 79 of Worksheet A, in the section titled “Cost Other Than RHC Services”
• FQHCs must report both originating and distant site telehealth costs on Form CMS-224-14, the Federally Qualified Health Center Cost Report, on line 66 of Worksheet A, in the section titled “Other FQHC Services”

Since telehealth distant site services are not paid under the RHC AIR or the FQHC PPS, the Medicare Advantage (MA) wrap-around payment does not apply to these services. Wrap-around payment for distant site telehealth services will be adjusted by the MA plans.

Accelerated/Advance payments

An accelerated/advance payment is a payment intended to provide necessary funds when there is a disruption in claims submission and/or claims processing.

CMS announced on Sunday April 26, 2020 that they were reevaluating the amounts paid under the accelerated payment program, and suspending the Advance Payment Program to Part B suppliers.

Additional information is available here.

Resources:

• List of Approved Telehealth Services
• CMS: Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency – Interim Final Rule with Comment Period
• CMS.gov Press Release:  CMS Reevaluates Accelerated Payment Program and Suspends Advance Payment Program
• MLN Matters:  New and Expanded Flexibilities for RHCs and FQHCs During the COVID-19 PHE
• CMS: COVID-19 FAQs on Medicare Fee-for-Service Billing