Trying to figure out how to get paid for telehealth? *
*Doing audio-only? Coding and policies for audio-only telehealth are different. This blog focuses only on two-way audio/video telehealth.
If you thought it was bad in 2021, when you just had to deal with whether to use Place of Service (POS) 02 versus 11, and modifier -GT versus -95, now there’s a new complication.
Announced by CMS on October 13, 2021, the new place of service code (POS) for telehealth is 10, and it indicates telehealth when the patient is receiving services at home. Meanwhile, POS 02 has been shifted to denote that the patient is somewhere other than at home.
Don’t ask me why they felt it was necessary to make this distinction…
Next year, there will be a place of service for the bathroom.
When announcing the new POS 10, CMS originally stated that the implementation date for Medicare was April 4, 2022. However, the renewal of the Public Health Emergency (PHE) on April 13, 2022, trumps Medicare’s implementation of POS 10, because, according to the emergency waivers issued at the start of the COVID-19 pandemic, the telehealth flexibilities put in place as of March 6, 2020, will last until the end of the PHE (currently set for July 15, 2022).
Therefore, until the declared end of the PHE, coding telehealth for Medicare is still POS 11 (or whatever POS you would have used prior to the pandemic), plus modifier -95. This also applies to Medicare Advantage and Dual (Medicare + Medicaid) commercial plans.
Note: Medicare will pay for POS 10 (and 02) during the PHE, but coding POS 02 or 10 will impose a rate reduction.
This is because according to pre-pandemic Medicare telehealth policy, telehealth was subject to fee reductions. Medicare instituted the COVID telehealth billing flexibilities so as not to have to reprogram their payment systems, and also to ensure that healthcare providers could stay in business – sort of an important consideration during a worldwide pandemic.
What about commercial payers?
That’s the problem. Unlike Medicare and other government payers for whom billing instructions are a matter of public record, private payers don’t always openly disclose what they expect regarding telehealth coding – or they do, but it is often unclear, incomplete, and/or they make it so hard to find that it takes hours of searching.
Why is this so difficult? I just want to know how I can get paid for telehealth! Why can’t they all agree on how to bill it?
If I had the answer and solution to this problem, I would be able retire to Bora Bora tomorrow and you would have to find another Billing Buddy.
It’s frustrating, but right now everything depends on the payer and the policies they have implemented with regard to billing for telehealth. Some payers simply follow the lead of CMS. Others do their own thing…and they aren’t always consistent about it, either.
Your Billing Buddy’s recommendations for commercial payers:
- Check the payer’s website to see what (if any) instructions exist regarding billing for telehealth. I typically start by looking at the links marked “COVID-19” and then clicking around randomly until I get to information about telehealth and, hopefully, information about how to bill it.
- If you DO find something definitive, print it out. This will give you a snapshot of the date you obtained the information. Save it – you never know when you might need it in case of a clawback / recoupment attempt.
- Maintain a log or spreadsheet of the telehealth billing policy / coding requirements of the payers you bill most often.
- If you have time, feel free to call the payer, just don’t be surprised if it takes you a long time on the phone and at the end of the call you are more frustrated (but no more enlightened) than you were an hour or two previously.
- Subscribe to payer newsletters, blogs, and watch for webinars and trainings they offer.
- When in doubt, stick with POS 02 as long as the PHE remains in effect.
- If am unsure whether POS 10 is acceptable yet, but think it appropriate to try, I send in one test claim. I make note on my spreadsheet of the patient account #, date of service, and date submitted. Then, before submitting any more, I wait until it is adjudicated. Once I have my answer, I correct and release the remainder of claims that I have put on hold. That way, if the claim does get denied or underpaid, a single claim can be corrected quietly, without a large number of claims needing correction.