Telemedicine in RHCs and FQHCs

In April, 2020  CMS released guidance about paying for telehealth services in Rural Health Centers (RHCs) and Federally Qualified Health Centers (FQHCs). These payments were authorized by the CARES Act passed at the end of March, but CMS had yet to issue instructions for how RHC’s and FQHC’s could be paid for telehealth services.

For services provided using telemedicine (real-time, interactive, audio and visual) between Jan. 27, 2020 (the day the public health emergency was declared) and June 30, 2020, CMS says to add modifier 95, synchronous telemedicine services rendered via real-time interactive audio and visual video telecommunication system, on the claim.

CMS notes that RHCs will be paid at the all-inclusive rate (AIR) and FQHCs will be paid at the Prospective Payment System (PPS) rate. CMS states, in bold,

“These claims will be automatically reprocessed in July when the Medicare claims processing system is updated with the payment rate. RHCs and FQHCs do not need to resubmit these claims for the payment adjustment.”

This is somewhat puzzling to me. Any claims for telehealth services prior to this instruction probably were not submitted to CMS. It seems to me they would need to be resubmitted with modifier 95 appended. For services going forward via telehealth, until June 3, 2020, use modifier 95.

For telehealth services performed starting July 1, 2020 until the end of the public health emergency use HCPCS code G2025 to identify services that were furnished via Tele health in an RHC or an FQHC these claims will be paid at the $92 rate.

• The visit must use real-time, interactive, audio and visual telecommunication systems
• Practitioners can furnish these services from any location, including home

Although CMS says that RHCs and FQHCs can also bill on-line digital E/M codes, 99421—99423 and virtual communication code G2012 and G2010, these are reported with HCPCS code G0071.

MACs will automatically reprocess claims with G0071 for claims processed after March 1, 2022. The new rate is a blended rate, based on the payment rates of 99421—99423, and the two HCPCS codes for virtual communication, G2012 and G2010. There are articles about those services on CodingIntel.

Download the MLN Matters article SE 20016.