FAQs Medicare fee-for-service billing

CMS released an updated COVID-19 FAQ on Medicare fee-for-service billing for COVID-19 related services. The policies in the article are effective for the duration of the PHE unless superseded by future legislation. With 41 sections and over 200 questions and answers, we highlighted key information below.

Physician Services

Question: What does the IFC change for physician and practitioner billing?

  • Answer: With the revision of certain Medicare regulations, the IFC makes temporary changes to certain policies regarding
    • Supervision by a physician or non-physician practitioner
    • Payment for certain services furnished by teaching physician and moonlighting residents
    • Telehealth and other communication technology-based services
    • Services provided by Rural Health Clinics (RHCs) and Federally Qualified Health Centers
      • (FQHCs)
      • Payment to laboratories for specimen collection

Question: What are the changes to supervision?

  • Answer: 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 and hospital outpatient services.

Question: When do the changes on supervision take effect, and for how long?

  • Answer: 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

Question: Can medical groups contracted to provide care at local hospitals bill Medicare for covered professional services at temporary expansion sites.

  • Answer: Yes. Practitioners would bill under the Medicare Physician Fee Schedule and following existing billing rules for services furnished in the hospital. Practitioners should add the modifier “CR” to professional claims for patients treated in temporary expansion sites during the PHE.
General Billing Questions

Question: Regarding the use of the condition code “DR” and modifier “CR,” should these codes be used for all billing situations relating to COVID-19 waivers?

  • Answer: Yes. Except for telehealth services, the use of the “DR” condition code and “CR” modifier is mandatory for institutional and non-institutional providers in billing situations related to COVID-19 for any claim for which Medicare payment is conditioned on the presence of a “formal waiver.”

For the full list of FAQs on Medicare fee-for-service billing, please click here: CMS COVID-19 FAQ on Medicare fee-for-service billing

Source: CMS

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