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FAQs on Medicare Billing for Physicians in COVID-19 Pandemic

CMS is revising certain Medicare regulations to ensure that sufficient health care items and services are available to meet the needs of individuals enrolled in the Medicare program during the public health emergency (PHE) resulting from the COVID-19 pandemic. To that end, the IFC makes temporary changes to certain policies that will affect Medicare billing for Physicians in COVID-19 Pandemic.

Those changes are as follows:

  • Supervision by a physician or non-physician practitioner
  • Payment for certain services furnished by teaching physicians and moonlighting residents
  • Telehealth and other communication technology-based services
  • Services furnished by Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs)
  • Payment to laboratories for specimen collection

In general, CMS is revising the definition of direct supervision to include, during the PHE, a virtual presence through the use of interactive telecommunications technology, for services paid under the Physician Fee Schedule as well as for hospital outpatient services. The revised definition of direct supervision also applies to pulmonary, cardiac, and intensive cardiac rehabilitation services during the PHE. Additionally, CMS changed the supervision requirements from direct supervision to general supervision, and to allow general supervision throughout hospital outpatient nonsurgical extended duration therapeutic services.

Most other therapeutic hospital outpatient services have been subject to general, rather than direct, supervision requirements since January 1, 2020. General supervision means that the procedure is furnished under the physician’s overall direction and control, but that the physician’s presence is not required during the performance of the procedure. General supervision may also include a virtual presence through the use of telecommunications technology but we would note that even in the absence of the PHE general supervision could be conducted virtually, such as by audio-only telephone or text messaging. The changes to supervision rules are effective for services beginning March 1, 2020, and last for the duration of the COVID-19 Public Health Emergency.

FAQs on Medicare Billing for Physicians and Practitioners

Are there any changes in how hospitals account for the resident time at alternate locations?

Existing regulations have specific rules on when a hospital may count a resident for purposes of Medicare graduate medical education payments. Currently, if the resident is performing activities within the scope of his/her approved program in his/her own home, or a patient’s home, the hospital may not claim the resident. CMS is changing the regulations so if the resident is at home or in a patient’s home, but performing duties within the scope of the approved residency program and meets appropriate physician supervision requirements, a hospital that is paying that resident’s salary and fringe benefits can claim that resident for IME and DGME purposes. This allows residents to perform their duties in alternate locations, including their home or a patient’s home, so long as it meets appropriate physician supervision requirements.

Can residents furnish telehealth services?

Through this interim final rule, for the duration of the PHE for the COVID-19 pandemic, CMS is allowing Medicare payment for services billed by teaching physicians when residents furnish telehealth services to beneficiaries under the direct supervision of the teaching physician which is provided by interactive telecommunications technology. Medicare may also make payment for services billed by the teaching physician under the so-called primary care exception under regulation at section 415.174 when a resident furnishes telehealth services to beneficiaries under the direct supervision of the teaching physician by interactive telecommunications technology.

Does Medicare pay for a doctor or non-physician practitioner (NPP) to furnish care in a beneficiary’s home?

Medicare pays for evaluation and management (E/M) and other services (e.g., injections, venipunctures.) furnished in a beneficiary’s home by a physician or NPP. Medicare pays for Medicare telehealth services, which include many services that are normally furnished in-person. Under the emergency declaration and waivers, these services may be provided to patients by physicians and certain non-physician practitioners regardless of the patient’s location. Additionally, Medicare makes the payment for a number of non-face-to-face services that can be used to assess and manage a beneficiary’s conditions. These services include care management, remote patient monitoring, and communication technology-based services, e.g., remote evaluation of patient images/video and virtual check-ins.

Importantly, Medicare will also pay physicians for care furnished in the patient’s home by auxiliary personnel as long as those services are furnished incident to a physician’s service and as long as the practitioner is providing appropriate supervision through audio/video communication when needed. In addition to personnel employed by the physician, this could potentially also include clinicians leased from other entities (e.g., a home health agency, home infusion provider, or ambulance provider). In these circumstances, payment for such services would be made to the billing practitioner who would then make the appropriate payment to the contracting entity (for example, the home infusion provider).

Can the distant site practitioner furnish Medicare telehealth services from their home? Or do they have to be in a medical facility?

There are no payment restrictions on distant site practitioners furnishing Medicare telehealth services from their home during the public health emergency. The practitioner should report the place of service (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.

The ambulatory surgical center (ASC) in my community has recently converted to a hospital under unique provisions available during the PHE and my medical group has been contracted to provide care there. If clinicians from our medical group furnish covered professional services to Medicare beneficiaries at the ASC-turned-Hospital, can we bill Medicare for non-surgical services?

Yes. Physicians and other practitioners who are permitted to bill under Medicare can bill Medicare for covered professional hospital services that are furnished to Medicare beneficiaries at an ASC that temporarily enrolls as a hospital during the PHE. Practitioners would bill under the Medicare Physician Fee Schedule and follow existing billing rules for care furnished in a hospital. Practitioners should use the applicable place of service code depending on whether the ASC-turned-hospital is furnishing outpatient or inpatient care. Also, practitioners should add the modifier “CR” to professional claims for patients treated in temporary expansion sites during the Public Health Emergency.

My medical group is contracted to provide care at a local hospital. The hospital has built a tent, transitioned a gymnasium, or converted another non-clinical location into space to provide patient care. If clinicians from our medical group furnish covered professional services to Medicare beneficiaries at those new patient care locations, can we bill Medicare?

Yes. Physicians and other practitioners who are permitted to bill under Medicare can bill Medicare for covered professional services that are furnished to Medicare beneficiaries at temporary expansion sites, including gymnasiums, or other non-clinical locations. Practitioners would bill under the Medicare Physician Fee Schedule and following existing billing rules for services furnished in the hospital. Practitioners should use the applicable place of service code depending on whether the temporary expansion site is furnishing outpatient or inpatient care. Also, practitioners should add the modifier “CR” to professional claims for patients treated in a temporary expansion site during the PHE.

The state or the Army Corps of Engineers, or other governmental entity established a new care location in our area by repurposing and retrofitting a convention center, gymnasium, or other sites for patient care. My medical group has been asked to provide patient care in one of these locations. Can we bill Medicare for covered professional services furnished in these locations? If so are there reporting or billing rules that determine how this is done?

Yes. Physicians and other practitioners who are permitted to bill under Medicare can bill Medicare for covered professional services that are furnished to Medicare beneficiaries at temporary expansion sites, including those established by the state, the Army Corps of Engineers, or other governmental entities. Practitioners would bill under the Medicare Physician Fee Schedule and following existing billing rules for services furnished in the hospital. Practitioners should use the applicable place of service code depending on whether the temporary expansion site is furnishing outpatient or inpatient care. Also, practitioners should add the modifier “CR” to professional claims for patients treated in a temporary expansion site during the PHE.

Visit our blog section for more billing resources on COVID-19 and Medicare Billing. These resources will help you to prepare your practice and address patient concerns during the COVID-19 pandemic. To get reimbursed for medical services rendered during COVID-19 pandemic, contact Medical Billers and Coders (MBC) at 888-357-3226/info@medicalbillersandcoders.com

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