CMS Pushes Supplementals to Recognize Telehealth Crossover Claims

Nathan Baugh


As many of you have noted on the NARHC forums, telehealth visit (G2025) crossover claims were (and are) being denied. 

We began investigating this issue and learned that the CMS contractor for “edit validation” failed to load G2025 into their system until May 27th. This means that crossover claims submitted during this time need to be resubmitted directly to the supplemental. In other words, it was actually a CMS issue that caused these rejections for most of the month of May.

If crossover claims submitted after May 27th were rejected, then those claims were inaccurately processed by the supplemental payer. The supplemental payers are supposed to be processing them accurately and CMS today sent a notice to the supplemental payer plans that these claims needed to be processed. In other words, rejections on crossover G2025 claims submitted after May 27th are the fault of the supplemental payer.

The following notice is what the CMS staff sent to the supplemental payers after NARHC brought this to their attention. Hopefully, the following message combined with the CMS edit will allow these G2025 crossover claims to process correctly going forward.


This is the message CMS sent to the supplemental payers on this issue:

COBVA Alert--COBA Trading Partner Non-Recognition of HCPCS G2025 & Actions Needed to Address This Issue

The Centers for Medicare & Medicaid Services (CMS) was recently alerted that numerous supplemental insurers and benefit programs are not recognizing HCPCS G2025 when received on Rural Health Clinic (TOB 071x) and Federally Qualified Health Clinic (TOB 077x) claims via the Coordination of Benefits Agreement (COBA) crossover process.

Background:  The policy to use G2025 for RHC or FQHC telehealth clinic services was made official on April 30, 2020.  However, the effective date of the HCPCS was actually January 27, 2020.

For more information on HCPCS G2025 and related matters involving RHC and FQHC claims, the CMS COBA team invites its COBA trading partners to review the April 30, 2020 CMS MedLearn Matters Article, entitled “New and Expanded Flexibilities for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) During the COVID-19 Public Health Emergency (PHE),” which may be accessed at: 

Important Special Note:  The only aspect of the April 30, 2020 communication, referenced above, that has changed is a small segment of the information included as part of “Cost Sharing Related to COVID-19 Testing” (see page 4 of 7).  In that section, CMS had indicated that the Part A Medicare Administrative Contractors (MACs) will automatically reprocess RHC and FQHC claims where “CS” modifier was applied and yet coinsurance was reflected as due beginning on July 1, 2020. In reality, as CMS communicated via a May 20, 2020 COBVA notice, the action to reprocess these RHC and FQHC claims actually began the week of May 20th.

Actions Needed by COBA Trading Partners:

  • If you are a COBA trading partner that accepts RHC and/or FQHC crossover claims, please review your adjudication actions for the past several weeks to ensure you did not reject or deny claims that contained HCPCS G2025.
  • If you have rejected or denied RHC or FQHC claims that contained HCPCS G2025 for an RHC or FQHC telehealth clinic visit, CMS requests that you take any necessary actions, as soon as possible, to load G2025 into your HCPCS table or systematic processes.Additionally, once your system recognizes HCPCS G2025 as valid, RHC and FQHC providers will greatly appreciate reprocessing of rejected or denied claims that contained HCPCS G2025.

The CMS and Benefits Coordination & Recovery Center (BCRC) COBA teams greatly appreciate the swiftness with which our COBA trading partners address issues relating to non-acceptance of valid HCPCS codes and thank you in advance for your action.

Direct questions regarding this broadcast to your dedicated BCRC COBA EDI representative.

Thank you.

Nathan Baugh
Director of Government Affairs