4/28/2020
The Department of Health and Human Services (HHS) has published guidelines on how physicians and practitioners should bill telehealth services in order to be reimbursed at the same rate as if the service took place in an office setting. HHS has instructed physicians and practitioners to bill using the place of service code that would indicate where the service would have been provided outside of the COVID-19 pandemic, along with modifier 95 to indicate telehealth service. The continued use of POS code 02 could result in the service having a facility reduction applied.
The CMS 1744 Interim Final Rule issued 03/31/2020 includes the following summary:
“To implement this change on an interim basis, we are instructing physicians and practitioners who bill for Medicare telehealth services to report the POS code that would have been reported had the service been furnished in person. This will allow our systems to make appropriate payment for services furnished via Medicare telehealth which, if not for the PHE for the COVID-19 pandemic, would have been furnished in person, at the same rate they would have been paid if the services were furnished in person. Given the potential importance of using telehealth services as means of minimizing exposure risks for patients, practitioners, and the community at large, we believe this interim change will maintain overall relativity under the PFS for similar services and eliminate potential financial deterrents to the clinically appropriate use of telehealth. Because we currently use the POS code on the claim to identify Medicare telehealth services, we are finalizing on an interim basis the use of the CPT telehealth modifier, modifier 95, which should be applied to claim lines that describe services furnished via telehealth. We note that we are maintaining the facility payment rate for services billed using the general telehealth POS code 02, should practitioners choose, for whatever reason, to maintain their current billing practices for Medicare telehealth during the PHE for the COVID-19 pandemic.”