As coding and billing regulations continuously change, the content of this article may not be the most up-to-date information and is not intended to take the place of either the written policies or regulations. We encourage participants to review the specific regulations and other interpretive materials as necessary.
The COVID-19 Public Health Emergency (PHE) continues to disrupt most aspects of our lives. Healthcare facilities, in particular, have had to make rapid changes in the way they provide care to patients – which in turn has created a lot of confusion regarding how to bill payers and receive fair compensation for those services. The Centers for Medicare & Medicaid Services (CMS) recently provided additional guidance to facilities related to reporting “remote services” furnished to patients of a provider-based department of the hospital.
In April of this year, CMS introduced a temporary extraordinary circumstances relocation policy which allowed hospitals to temporarily relocate hospital departments to multiple locations in order to address care needs during the public health emergency. This policy allowed hospitals to designate patients’ homes as off-campus provider-based departments of the hospital when providing care to registered outpatients of the facility, which allowed hospitals to bill and be reimbursed for costs associated with providing services to patients using telecommunications technology.
Unfortunately, this policy also created a great deal of confusion and inconsistency among providers regarding which code to bill when providing remote clinic visits: G0463, Hospital outpatient clinic visit for assessment and management of a patient, or Q3014, Telehealth originating site facility fee. Fortunately, CMS recently published updated guidance to assist hospitals with selecting the appropriate code based on the services provided.
When deciding which code to report for services provided, hospitals need to consider the services they are providing and the location of the physician.
What exactly does this mean for hospitals? In a nutshell, services provided remotely using telecommunications technology between a physician in the hospital and a patient whose home has been temporarily designated as an offsite provider-based department of the hospital are considered to be provided in the hospital for billing purposes. In general, it will be appropriate for hospitals to report HCPCS code G0463 just as they would if the patient was physically located in the hospital. Similarly, therapy services that can safely be provided using telecommunications technology by hospital-employed therapists should be billed as though the service was provided in person. The same goes for if a hospital employee travels to the patient’s home to provide services, the services may be billed as though they were provided in the hospital.
It is important that hospitals append either modifier PN or modifier PO when billing for services provided via telecommunications technology in accordance with the previously-published guidance related to the extraordinary circumstances relocation policy. As a reminder, modifier PO is appropriate when the provider has requested to temporarily relocate an on-campus or excepted off-campus department of the hospital within 120 days of providing services in the expanded location(s) (which may include patients’ homes). Modifier PN would be used if a non-excepted off-campus department of the hospital is providing the services or if the hospital chooses not to request temporary relocation of their departments.
For more help, be sure to check out our other webinars and articles related to COVID-19 coding and billing guidelines.