As of January 1, 2020, CMS pays Opioid Treatment Programs (OTPs) through bundled payments for opioid use disorder (OUD) treatment services in an episode of care provided to people with Medicare Part B (Medical Insurance). As of January 1, 2021, Medicare Part B covers hospital outpatient OTP services. All the below-mentioned telecommunication billing updates for OTPs are effective from Jan’22 while implementation will start from March’22.
Telecommunication Billing Updates for OTPs
- OTPs can use two-way interactive audio-video communication technology, as clinically appropriate, to furnish the substance use counseling and individual and group therapy services included in the bundled payment, as well as the add-on code for additional counseling and therapy.
- Additionally, beginning January 1, 2021, OTPs can use two-way interactive audio-video communication technology, as clinically appropriate, to furnish the periodic assessment add-on code.
- During the Public Health Emergency (PHE) for the COVID-19 pandemic, as well as after the conclusion of the PHE, the therapy and counseling portions of the weekly bundles of services furnished by OTPs, as well as any additional counseling or therapy payable under the add-on code for additional counseling or therapy, may be furnished using audio-only telephone calls rather than via two-way interactive audio-video communication technology during the PHE for the COVID-19 pandemic if beneficiaries do not have access to two-way audio/video communications technology, provided all other applicable requirements are met.
- Additionally, during the PHE, periodic assessments may be furnished via two-way interactive audio-video communication technology, as clinically appropriate, and in compliance with all applicable requirements, and in cases where a beneficiary does not have access to two-way audio-video communications technology, periodic assessments can be furnished using audio-only telephone calls during the PHE if all other applicable requirements are met.
- After the conclusion of the PHE for the COVID-19 pandemic, CMS expects OTPs to add Modifier FQ (The service was provided using audio-only communication technology) to the claim for counseling and therapy provided via audio-only telecommunications using HCPCS code G2080.
- Additionally, after the conclusion of the PHE for the COVID-19 pandemic, CMS expects OTPs to add Modifier 95 (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) to the claim for counseling and therapy provided via audio-video telecommunications using HCPCS code G2080.
- As OTP services are not PFS services, no originating site facility fee (HCPCS code Q3014) applies to OUD treatment services, and OTPs are not authorized to bill for the originating site facility fee. Additionally, the payment for the substance use counseling and individual and group therapy are included in the bundled payment rates made to OTPs; therefore, the practitioner furnishing the service remotely should not bill separately for the service.
We shared site of service (telecommunication) updates for OTPs from the Medicare Claims Processing Manual – Chapter 39 for reference. Medical Billers and Coders (MBC) is a leading medical billing company providing complete revenue cycle services.
To know more about our billing and coding services, contact us at info@medicalbillersandcoders.com/ 888-357-3226
FAQs
1. What are the telecommunication billing updates for OTPs?
Starting January 2022, OTPs can use two-way audio-video communication for counseling, therapy, and periodic assessments, and audio-only calls are allowed if beneficiaries lack video access.
2. Can OTPs use audio-only calls for therapy and assessments?
Yes, during the COVID-19 Public Health Emergency (PHE), OTPs can provide therapy and assessments via audio-only calls, if the required conditions are met.
3. What modifier should be used for audio-only therapy after the PHE?
After the PHE, OTPs must use Modifier FQ for audio-only therapy and Modifier 95 for audio-video therapy when billing for services provided via telecommunication.
4. Are OTPs allowed to bill for an originating site facility fee?
No, OTPs are not authorized to bill for the originating site facility fee (HCPCS code Q3014) since OUD treatment services are not subject to the Physician Fee Schedule.
5. Are OTP services included in bundled payments?
Yes, OTP services like counseling and therapy are included in the bundled payment rates, and practitioners should not bill separately for these services.
