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RHC Modifier HCSPC conflict 11721
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9/2/2020 @ 9:31:00 AM
Post 1 of 19

Contributor: Julie York, Marengo Family Medical Clinic

We began getting denials for 11721/CG starting July.  I called Medicare and they stated that we should no longer use the CG modifier after July 1, 2020. I found something stating that the following codes were added to the RHC Modifier HCPCS Conflict list: 10060, 11721, 12001, 20604. 

Has anyone else found information on this and understand exactly what and why this is being done?  And am I correct that we should no longer add the CG modifier to any of these? 



9/2/2020 @ 11:27:00 AM
Post 2 of 19

Contributor: Joanne Bean, McCrary Rost Clinic - Lake City

We are seeing the same denials but the biller had not yet called Medicare.  Thank you for posting this question and will be following.
9/2/2020 @ 11:49:00 AM
Post 3 of 19

Contributor: Lisa Engelman, NMRMC Family Medicine

Through my research and some information I found from previous threads,  one can find RHC Modifier HCPCS Conflict Addition lists.  I just searched for it on the CMS website. The code above was added in July.


9/2/2020 @ 1:52:00 PM
Post 4 of 19

Contributor: Cassie Beesley, Springfield Clinic - Hillsboro East

We are having some issues to with the codes that were added to the conflict lists in January. Particularly 69210 for us. What they are saying is that these codes cannot be billed by themselves on a claim, as they are no longer eligible to have the CG. They can be billed with an E/M or another QVL code that has the CG and then charges rolled into the CG line. But they are no longer eligible to be billed by themselves with the CG. This is an issue because they still have not updated the QVL list that we go by for this to reflect these changes. We have tried to fight this with Palmetto with no success because they are going by the new conflict lists and not the QVL. I know this has been taken to CMS to review, because often many of these codes would be billed by themselves. So basically if we don't have enough to justify billing an E/M along with those codes we are basically just out, as we cannot bill the patient.

[cid:image003.png@01D4EA20.04F19020] Cassie Beesley, CRHCP
Rural Health Clinic Manager
Springfield Clinic
Phone 217.528.7541 x44801

9/2/2020 @ 4:17:00 PM
Post 5 of 19

Contributor: Jackie King, Illinois Critical Access Hospital Network

Hi All,

I have talked with Nathan Baugh and he is aware and is working on this issue with CMS.

Thank you,


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 | |

9/10/2020 @ 3:40:00 PM
Post 6 of 19

Contributor: Julie York, Marengo Family Medical Clinic

Are there any updates on this?

9/10/2020 @ 4:07:00 PM
Post 7 of 19

Contributor: Nathan Baugh, National Association of Rural Health Clinics

CMS created a "RHC Modifier HCPCS Conflict Additions" list in April of 2018.

If a code is on this list, it means that CMS has told the MACs to reject claims with that code and modifier CG. The end policy is that CMS has determined that these services DO NOT meet the definition of a RHC encounter. NARHC is gathering all relevant information on this issue and will be pursuing this issue further with CMS. We may need to contest CMS determinations on a code-by-code basis. 

I believe 7 codes were on this list in 2018 and then 11 more were added through the course of 2020 for a total of 18 HCPCs codes on this list. Right now, I only have the 11 codes added in 2020 but I am working to identify the other 7.

11721 was added to this list in July so I am not surprised you are getting a rejection. We will post a full list (with code descriptions) when we have it on our website. These are the 11 codes added to the list in 2020:



9/10/2020 @ 5:35:00 PM
Post 8 of 19

Contributor: Shirley Gamble, Sterling Medical Center

So Nathan, are you needing claim examples? Can you explain the "doesn't
meet an RHC encounter definition"? Does that mean we can bill Part B and
carve out time and supply costs for these services?

*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 Thu, Sep 10, 2020 at 3:09 PM NARHC News

9/10/2020 @ 5:47:00 PM
Post 9 of 19

Contributor: Patty Harper, InQuiseek Consulting

It means that those codes cannot be appended with -CG. They can be
additional codes on the claim if they are a separate service. They would
not be carved out or split billed. They would be incidental to other RHC


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9/10/2020 @ 5:51:00 PM
Post 10 of 19

Contributor: Debra Raines, Rush Health Systems

What if that is the only service done on that day? The charge is not billable at all?

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