Billing for Telehealth Services During COVID-19: An Overview for Federally Qualified Health Centers

May 28, 2020 | Covid-19, Health Care

Federally qualified health centers (“health centers”) have the opportunity to utilize telehealth to continue serving their communities during the COVID-19 Public Health Emergency. As implementing telehealth is likely a new experience for most health centers, knowing what to bill and how to bill for telehealth services becomes a vital inquiry. Here are a few things to consider. 

Telehealth billing requirements under HRSA

Telehealth billing requirements under HRSA requires compliance with any requirement associated with billing and reimbursement for telehealth visits/activities, including those imposed by states or third party payor sources (e.g., Medicare, Medicaid, Children’s Health Insurance Program (CHIP), private insurance). 

Telehealth billing requirements under Medicaid

In order to deliver services and ensure the needs of participants are met, Idaho Medicaid encourages providers to look to utilize telehealth options, where appropriate. Reimbursement is available for services provided under Idaho Medicaid’s telehealth policy, which has procedure codes for both new and established patients, including primary care. To inhibit the spread of the virus, and to respond to the societal disruptions taking place, Idaho Medicaid has immediately moved to reimburse for a wide array of services under a telehealth option and expand providers authorized under our telehealth policy. Information Release MA18-007 on Medicaid telehealth policy is temporarily rescinded. Claims must be billed with the GT modifier on the CPT, HCPCS, or revenue code. FQHC, RHC, and IHC providers billing the T1015 encounter code should not add the GT modifier to the encounter code but should add the GT modifier to the supporting codes.

Telehealth billing requirements under Medicare/Medicare has approved the use of telehealth for certain services that generally occur in-person. Generally, when providing the approved telehealth services, the provider must use an interactive telecommunications system that includes both audio and video and permits real-time communication between the distant site and the patient at home. On April 30, 2020, Medicare released guidance allowing for some telehealth services to be conducted via audio-only and provided specific billing codes for audio-only services.

For telehealth distant site services that are also FQHC qualifying visits, furnished between January 27 – June 30, 2020, FQHCs must report three HCPCS/CPT codes for distant site telehealth services provided via audio and video: 1) the Prospective Payment System specific payment code; 2) the HCPCS/CPT code that describes the services furnished with modifier 95; and 3) the G2025 HCPCS code with modifier 95. If services are audio-only, modifier 95 is not necessary. Claims will be paid at the FQHC PPS rate until June 30, 2020, and then automatically reprocessed beginning July 1, 2020, at the $92.03 rate, without any need to resubmit for payment adjustment.

When the distant site services are not FQHC qualifying visits, CMS advises the FQHC to hold such claims until July 1, 2020. After July 1, 2020, the health center should then bill these services with HCPCS code G2025. 

Beginning July 1st, FQHCs will only be required to submit G2025 when billing all telehealth services. 

It is important to note that these changes are not permanent, and only apply during the COVID-19 pandemic. Before providing telehealth services, confirm these expansions are still in place. If you have questions implementing telehealth services or questions about telehealth billing at your health center please contact Smith + Malek to learn more about how we can help. 

This blog post is designed to provide general information on pertinent legal topics. The statements made are provided for educational purposes only. This blog does not provide legal advice. This blog does not create an attorney-client relationship between you and Smith + Malek, PLLC. If you want to create an attorney-client relationship and have specific questions regarding the application of the law to your own circumstances, you should contact our office.