COVID-19 HCCI Update: Week of 03/30/20

During HCCI’s recent webinar, “The Impact of COVID-19 on Home-Based Providers, Practices, and Patients we encouraged practices to reach out to their local Medicare Administrator Contractors (MAC) for specific guidance on whether home-based primary care (HBPC) providers can bill for the home and domiciliary visit CPT code ranges under the 1135 telehealth waiver.

New Centers for Medicare & Medicaid Services (CMS) Fact Sheet

On March 30, CMS published an important new fact sheet announcing that they’re adding 80 additional services when furnished via telehealth. CMS also added home and domiciliary CPT codes to the list. These codes can now be billed for when performed via telehealth using two-way audio and video.

Following are the home and domiciliary visits added for payment during the COVID-19 Public Health Emergency:

• New patient domiciliary visits CPT code 99327 (Level 4 New/60 minutes) and CPT 99328 (Level 5 New/75 minutes)
• Established patient domiciliary visits CPT code range 99334-99337 (complete levels of service 1-4)
• New patient home visits CPT code range 99341-99345 (complete levels of service 1-5)
• Established patient home visits CPT code range 99347-99350 (complete levels of service 1-4)

Please note that CMS advised they expect providers to use the Evaluation & Management (E/M) code that best describes the nature of the care they are providing, regardless of the physical location or status of the patient (e.g., HBPC providers using home and domiciliary visits rather than the office visit code set).

As a result of the new interim final rule, CMS also did the following:

NEW MODIFIER and Place of Service REQUIREMENTS

• Finalized its interim policy of requiring modifier 95 for E/M services furnished via telehealth. CMS no longer requires the use of Place of Service 02 for telehealth; instead, providers are instructed to report the POS that would have been reported if the visit was conducted face-to-face (e.g., POS 12 for home) and modifier 95 which identifies the service as telehealth. Following is a complete description:
  • Modifier 95 is used to indicate services performed via real-time interactive audio and visual telecommunication system.
  • You can also refer to the CMS interim final rule for a complete list of covered telehealth services.
• Added CPT code ranges for Telephone E/M services which allow for payment of audio-only interactions:
  • CPT 99441 Telephone E/M 5-10 minutes; National Facility Payment $13.32
  • CPT 99442 Telephone E/M 11-20 minutes; National Facility Payment $26.64
  • CPT 99443 Telephone E/M 21-30 minutes; National Facility Payment $39.60
• Other qualified healthcare professionals who can bill for telehealth services per CMS include licensed clinical social workers, clinical psychologists, physical therapists, occupational therapists, and speech-language pathologists. These providers can bill for telephone E/M services using the following CPT codes:
  • CPT 98966 Telephone E/M 5-10 minutes Non-Physician Practitioner; National Facility Payment $13.32
  • CPT 98967 Telephone E/M 11-20 minutes Non-Physician Practitioner; National Facility Payment $26.64
  • CPT 98968 Telephone E/M 21-30 minutes Non-Physician Practitioner; National Facility Payment $39.60
• Clarified that their interim policy for telephone E/M, virtual check-ins, and E-visits can now be furnished to new and established patients. POS 02 and modifier 95 should not be used in these instances since they are not considered to be “telehealth” services. Instead, the POS where the services would typically be rendered should be used.
• Retained the requirement that the Communication Technology-Based Services (CTBS), e.g., virtual check-ins and telephone E/M, described above cannot be related to an E/M visit within the past 7 days and cannot result in the need for a face-to-face visit or a telehealth E/M visit. (To see additional information on CTBS, refer to the links for the previous HCCI COVID-19 articles below.)

Additional Legislation Updates

• On March 25, the United States Senate passed H.R. 748 – the Coronavirus Aid, Relief, and Economic Security Act (The CARES Act).
  • The Home Centered Care Institute (HCCI) is pleased to announce that section 3708 of the CARES Act allows Nurse Practitioners (NP), Physician Assistants (PA), and Certified Nurse Specialists (CNS) to prescribe and certify home health services and be reimbursed for such services under Medicare Parts A & B.
  • With the new act, Advanced Practice Providers can now establish the plan of care and fulfill plan review requirements. This also applies to Medicaid requirements and must be implemented within 6 months of the date of enactment of the act.
• CMS also announced the Expansion of the Accelerated and Advance Payments Program, which may be beneficial for practices and providers struggling with cash flow issues due to COVID-19.
• Home Health and Hospice agencies also have increased flexibility in the types of services they can perform via telehealth, which is further described in the interim final rule.

Please continue to visit HCCI’s COVID-19 Information Hub When you’re on the site, look for the word “New,” which will flag the information added that week.

You can also join the conversation happening in the new Home Centered Care Institute COVID-19 Group on LinkedIn. Once you’re logged into LinkedIn, join your colleagues who are already members by searching the name of the group on LinkedIn and requesting to join – or by going directly to https://www.linkedin.com/groups/12383537/ to make the request.

Previous HCCI COVID-19 Update Articles:

• COVID-19 Preparedness and Screening Questions for HBPC Practices and Providers
• Providing Telephonic and Virtual Care Requirements as part of COVID-19 Precautions
• COVID-19 Telehealth Billing Requirements

Disclaimer: This information is current as of 4/1/2020. COVID-19 guidelines are changing daily. Please note for the purposes of the Home-Based Primary Care (HBPC) population: The Home Centered Care Institute (HCCI) focuses our content on CMS guidelines relevant for traditional Medicare billing. It’s always recommended to check with local MACs for specific guidance for your geographic region.