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| 5/14/2020 @ 3:58:00 PM
Post 1 of 21
Contributor: Connie Lovell, Beatrice Family & Internal Medicine
I heard on a webinar that when charging for these services, that the actual CPT code for the service provided should be entered in our practice management system, but the G2025 is the code that would go to Medicare.... so a 99214 or a G0438/G0439 would be entered in our billing system, but the code that would go to Medicare is the G2025 ... has anyone else heard that and billing that way??
Also, has anyone heard how the G0438 (initial AWV) done during this time will be tracked by Medicare to know that in a year they need the subsequent AWV (G0439) and not the initial? Thank you, Connie Lovell 5/15/2020 @ 10:07:00 AM
Post 2 of 21
Contributor: Sarah Brown, Confluence Health RHCs
I would be interested in clarity on this as well. Some one in my organization heard the same thing on a webinar. We think it is misinterpretation of the instructions from MLN SE20016 (revised) for FQHCs (not RHCs). The MLN on this topic was pretty clear for RHCs that only G2025 was to go on the claim.
5/15/2020 @ 10:27:00 AM
Post 3 of 21
Contributor: Bill Finerfrock, National Association of Rural Health Clinics - Retired
NARHC shares the concern regarding the limitation on telehealth claims to the G2025 code. We believe that for certain telehealth claims, the inclusion of the relevant HCPCS code is important to proper adjudication of the claim, particularly in instances where the co-insurance is waived or the code conveys important information about the service rendered during the telehealth visit.
We have asked CMS to clarify how RHCs are to communicate the relevant CPT information on the telehealth claims so that they can be properly paid and adjudicated. As soon as we receive a response, we will let you know. Bill 5/15/2020 @ 11:10:00 AM
Post 4 of 21
Contributor: Shirley Gamble, Sterling Medical Center
Using the Office Visit codes are only to track the level of care/time the
provider spends so this can be used for administrative purposes (production RVUs, carve out time for Cost Report on these services, etc.) The G2025 is the actual code that is being submitted for the RHC Distant Site Telehealth visit. How each practice decides to capture the above information will differ depending on individual practice decisions and the ability of their PM software. Most PM systems allow for the creation of billing rules based on a specific insurance, bill type etc. that will change information for the claim. *Shirley L Gamble, CPC* Clinic Coding Manager Sterling Medical Center 239 N Broadway Sterling, KS 67579 620.278.2123 Main 620.278.2712 Fax On Fri, May 15, 2020 at 9:09 AM NARHC News wrote: > 5/15/2020 @ 12:24:00 PM
Post 5 of 21
Contributor: Jackie King, ArchProCoding
Hi Everyone,
I have also submitted a comment addressing this question on the IFC page. I am looking at not only from a cost-sharing standpoint but also from an ACO standpoint where tracking and promoting AWV is a key performance metric and now that we have limited office hours we would love to be providing these via telehealth for our patients. At this time we have suggested that our ACO members do not perform these via telehealth until we can get further guidance from CMS. A huge thank you to Bill and NARHC for your push to get this clarification for all of us! You have been the source of truth for us throughout this PHE and we appreciate all that you do! Jackie [cid:image001.png@01D579EB.4BFCECC0] Jackie King, MSHI, CPC, COC, RH-CBS Director of Clinical Informatics, HIM Consultant Illinois Critical Access Hospital Network (ICAHN) | 1945 Van's Way, Princeton, IL 61356 P 815.875.2999 | F 815.875.2990 | jking@icahn.org 5/15/2020 @ 1:28:00 PM
Post 6 of 21
Contributor: Charles James, North American Healthcare Management Services
Dear all -
I am certain this email thread is referring to my recent statements on Mark Lynn's billing webinar, in which I helped moderate. I knew my commentary would create confusion and misunderstanding. I apologize for having contributed to that. I attempted to elaborate on this in the most recent NARHC newsletter, as well. My comments were a SUGGESTED billing method intended to reconcile the Medicare G2025 billing requirement with our own RHC/FQHC reporting needs. I emphasized in the webinar, and in the article, that this is a SUGGESTED posting method. Indeed, no service detail is to be submitted on RHC Telehealth G2025 claims. Per SE20016 April 30 Revision: https://www.cms.gov/files/document/se20016.pdf "RHCs and FQHCs must use HCPCS code G2025, the new RHC/FQHC specific G code for distant site telehealth services, to identify services that were furnished via telehealth beginning on January 27, 2020, the date the COVID-19 PHE became effective. Because these changes in policy were made on an emergency basis, CMS needs to implement changes to claims processing systems in several stages." January 27, 2020, and June 30, 2020 RHCs must report HCPCS code G2025 on their claims with the CG modifier. Modifier "95" (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) may also be appended, but is not required. These claims will be paid at the RHC's all -inclusive rate (AIR), and automatically reprocessed beginning on July 1, 2020, at the $92.03 rate. RHCs do not need to resubmit these claims for the payment adjustment. Beginning July 1, 2020, RHCs should no longer put the CG modifier on claims with HCPCS code G2025." Claim Issues: Because of ACO reporting requirements for quality metrics, Medicare Coordination of Benefits, physician compensation models based on RVUs, many of us feel the need to post the actual E/M service detail rendered during Telehealth visits. North American HMS, at our core, is a billing (RCM) company. We are resellers for, and host an EHR platform (eMD/Aprima). We are way down in the weeds on all of these issues. As I wrote in the newsletter: "G2025 is to be used for billing RHC/FQHC distant site Telehealth services. G2025 is an RHC/FQHC-specific HCPCS code. CMS does NOT want additional service detail to accompany the Distant Site Telehealth claims. For example, if Dr. Jones (fictitious) at North Country RHC (also fictitious) performs an Annual Wellness Visit via telehealth, G0439 is not to be submitted on the claim." "This presents many problems. First, there is no service detail for the Medicare Coordination of Benefits system to capture. Medicare will not "know" that Dr. Jones performed an Annual Wellness visit for that patient. Second, how will Medicare know that this service was preventive and should not have co-insurance or deductible amounts applied. Third, how will our ACOs or other entities know that the RHC is meeting quality measures? Next, Dr. Jones's compensation is based on RVUs (Relative Value Units). How would these services be captured on our cost report? How will that work?" Claim Detail* We are posting the actual E/M detail to our system, along with G2025. We are posting service detail as zero charges, but suppressing all line items except the G2025. (suppressing = not submitting on claims) We are also using Modifier-95. This will facilitate identifying these extra e/m codes. These will need to be excluded from our cost report visit count. Remember: Modifier CG is only required through June 30. Modifier-95 is NOT required but is optional. This billing method is a suggestion! (G0439 or other CPT detail should NOT go out on the claim). This method is only a suggested method of capturing service detail. *Caution! If you post in this manner, it will be essential NOT to count those 9921X, G043X, etc in your actual visit counts for cost reporting! That will definitely mess up your rate! NARHC Newsletter Link: https://myemail.constantcontact.com/NARHC-News-2020-Spring-Edition.html?soid=1112944541597&aid=nVCf78ZNa1w I am sorry for whatever confusion I caused with this. I knew it would. BUT - It is also a question everyone is asking. Best regards - Charles Charles A. James, Jr. President and CEO 888.968.0076 Office 314.560.0098 Cell www.northamericanhms.com This transmission contains privileged, confidential, and proprietary information and is only for the use of the individuals listed above, and may not be copied, distributed, or disseminated without express written consent. If you receive this transmission in error, please immediately destroy it. 5/26/2020 @ 6:27:00 PM
Post 7 of 21
Contributor: lrjarr@dchc.org
I am reading a revised version of SE20016 which was released on April 30, 2020. It says "Claims Requirements for RHCs
For telehealth distant site services furnished between January 27, 2020, and June 30, 2020, RHCs must report HCPCS code G2025 on their claims with the CG modifier. Modifier "95" (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) may also be appended, but is not required. These claims will be paid at the RHC's all-inclusive rate (AIR), and automatically reprocessed beginning on July 1, 2020, at the $92.03 rate. RHCs do not need to resubmit these claims for the payment adjustment. Beginning July 1, 2020, RHCs should no longer put the CG modifier on claims with HCPCS code G2025." ---------- Original Comments ---------- Last Post By: clovell@bchhc.org I heard on a webinar that when charging for these services, that the actual CPT code for the service provided should be entered in our practice management system, but the G2025 is the code that would go to Medicare.... so a 99214 or a G0438/G0439 would be entered in our billing system, but the code that would go to Medicare is the G2025 ... has anyone else heard that and billing that way?? 5/26/2020 @ 6:40:00 PM
Post 8 of 21
Contributor: Patty Harper, InQuiseek Consulting
On several webinars a number of us have been suggesting that the RHC track the actual service CPT but suppress it from going on the claim either in their system or at the clearinghouse level. Not all systems can do this but it would be helpful in knowing which service was done under the G2025 umbrella, which ones were preventive services and to track provider productivity. With everything going in under the G2025 code, there is no way to get credit for preventive services or to measure true utilization without an internal tracking service. We have continue to clarify why we think this is a good idea on subsequent webinars because it had been misunderstood.
Patty Harper, RHIA, CHTS-IM, CHTS-PW, CHCR Healthcare Consultant/Principal 318-243-2687 (Cell) 866-855-0683 (Fax) 940 Ratcliff Street Shreveport, LA 71104 The information contained in this transmission may contain privileged and/or confidential information, including patient information protected by federal and state privacy laws. It is intended only for the use of the person(s) named above. If you are not the intended recipient, you are hereby notified that any review, dissemination, distribution, or duplication of this communication is strictly prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. 5/26/2020 @ 7:13:00 PM
Post 9 of 21
Contributor: Charles James, North American Healthcare Management Services
Also Per SE20016: For telehealth distant site services furnished between January 27, 2020, and June 30, 2020, RHCs must report HCPCS code G2025 on their claims with the CG modifier... Beginning July 1, 2020, RHCs should no longer put the CG modifier on claims with HCPCS code G2025."
Charles A. James, Jr. President and CEO 888.968.0076 Office 314.560.0098 Cell www.northamericanhms.com This transmission contains privileged, confidential, and proprietary information and is only for the use of the individuals listed above, and may not be copied, distributed, or disseminated without express written consent. If you receive this transmission in error, please immediately destroy it. 5/27/2020 @ 12:14:00 AM
Post 10 of 21
Contributor: Alexander Giloff, Camino Family Medical Center
As far as I know, most electronic medical records (EMR) and Practice Management / Billing (PM) operate independent from one another even though it appears you are using a fully integrated solution. So, for example, when a progress note is completed and locked on the EMR side, the data can be used to create a claim on the PM side, and that newly created claim file can be altered without it disturbing the original note on the EMR side.
Thus, to maintain the integrity of the note while still only sending G2025, one could cause a 99441-3 telehealth code series to generate the G2025 CPT whenever they are selected. Once the note is completed and locked as such, the E/M and service detail would be preserved. Then moving over to the generated claim file, one could simply delete what is not required until the claim is properly set-up. We are using eClinicalworks, so I know it will work on this platform. For others, please make a few test-runs to verify the note maintains its format after changing the data on a claim. Alex Giloff Administrator Western Sierra Medical Center 3070 Camino Heights Drive, Suite B Camino, CA 95709 (530) 647-WSMC (9762) (530) 647-1961 FAX agiloff@wsmedicalcenter.com |
