Spotlight
Spotlights
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RHC Policies Addressed in the CY 2022 Physician Fee Schedule Final Rule
CMS issued the CY 2022 Medicare Physician Fee Schedule Final Rule which included several provisions that impacted RHCs. A list of provisions effective January 1, 2022 is outlined below. Information regarding each of these policies is available in the CY 2022 Medicare Physician Fee Schedule Final Rule Fact Sheet.
- Payment limit per visit changes for independent and provider-based RHCs
- Payment for attending physician services furnished by RHCs to hospice patients
- Concurrent Billing for Chronic Care Management Services (CCM) and Transitional Care Management (TCM) Services for RHCs
- Mental Health Services Furnished via Telecommunications Technologies for RHCs
- Change to the general care management HCPCS code G0511 to replace G2064 and G2065 with CPT code 99424 and 99426
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COVID-19 Public Health Emergency (PHE) - Updates for RHCs
To provide as much support as possible to RHCs and their patients during the COVID-19 (PHE), we have made several changes to RHC requirements and payments. These changes are for the duration of the COVID-19 PHE, and we will continue to review our policies as the situation evolves. For additional information and other flexibilities, please see the link: https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf (PDF)
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COVID-19 Vaccines in RHCs
COVID-19 vaccines and their administration will be paid the same way influenza and pneumococcal vaccines and their administration are paid in RHCs. Influenza and pneumococcal vaccines and their administration are paid at 100 percent of reasonable cost through the cost report. The beneficiary coinsurance and deductible are waived. For Medicare Advantage patients, RHCs and FQHCs should submit COVID-19 vaccine administration claims to the Medicare Advantage Plan for dates of service on or after January 1, 2022. Original Medicare won’t pay for these claims beginning in January 2022. For dates of service in 2021, RHCs and FQHCs should use the cost report to bill for administering COVID-19 vaccines. For additional information, please see https://www.cms.gov/covidvax.
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Payment for Telehealth Services for RHCs During the COVID-19 PHE
On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law. Section 3704 of the CARES Act authorizes RHCs to furnish distant site telehealth services to Medicare beneficiaries during the COVID-19 PHE. Medicare telehealth services generally require an interactive audio and video telecommunications system that permits real-time communication between the practitioner and the patient. RHCs with this capability can provide and be paid for telehealth services to patients covered by Medicare for the duration of the COVID-19 PHE.
Distant site telehealth services can be furnished by any health care practitioner working for the RHC within their scope of practice. Practitioners can furnish distant site telehealth services from any location, including their home, during the time that they are working for the RHC, and can furnish any telehealth service that is approved as a distant site telehealth service under the Physician Fee Schedule (PFS). A list of these services can be found here: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes. Claims for G2025 are paid at the CY2021 rate of $99.45. The CY 2022 rate is $97.24.
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Payment for Mental Health Visits Furnished by RHCs via Telecommunications
Beginning January 1, 2022, RHC mental health visits will include visits furnished using interactive, real-time telecommunications technology. This change will allow RHCs to report and receive payment for mental health visits furnished via real-time telecommunication technology in the same way they currently do when visits take place in-person, including audio-only visits when the beneficiary is not capable of, or does not consent to, the use of video technology. Therefore, we are finalizing that there must be an in-person mental health service furnished within 6 months prior to the furnishing of the telecommunications service and that in general, there must be an in-person mental health service (without the use of telecommunications technology) must be provided at least every 12 months while the beneficiary is receiving services furnished via telecommunications technology for diagnosis, evaluation, or treatment of mental health disorders. However, exceptions to the in-person visit requirement may be made based on beneficiary circumstances (with the reason documented in the patient’s medical record) and more frequent visits are also allowed under our policy, as driven by clinical needs on a case-by-case basis.
Section 304 of the CAA, 2022 delayed the in-person requirements under Medicare for mental health services furnished through telehealth under the PFS and for mental health visits furnished by RHCs via telecommunications technology. For RHCs, in-person visits will not be required until the 152nd day after the end of the PHE for COVID-19.
In order to bill for mental health visits furnished via telecommunications for dates of service on or after January 1, 2022, RHCs should bill Revenue code 0900, along with the appropriate HCPCS code for the mental health visit along with modifier CG. Use modifier 95 for services furnished via audio and video telecommunications and use modifier FQ for services that were furnished audio-only.
For additional information on payment, billing, and claims processing, see https://www.cms.gov/files/document/se20016.pdf (PDF)
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Expansion of Virtual Communication Services for RHCs During the COVID-19 PHE
During the COVID-19 PHE, payment for virtual communication services include digital assessment services. Digital assessment services are non-face-to-face, patient-initiated, digital communications using a secure online patient portal. The digital assessment codes that are billable during the COVID-19 PHE are CPT code 99421 (5-10 minutes over a 7-day period), CPT code 99422 (11-20 minutes over a 7-day period), and CPT code 99423 (21 minutes or more over a 7-day period).
To receive payment for the new digital assessment service or virtual communication services (HCPCS codes G2012 and G2010), RHCs must submit an RHC claim with HCPCS code G0071 (Virtual Communication Services) either alone or with other payable services. For claims submitted with HCPCS code G0071 on or after March 1, 2020, and for the duration of the COVID-19 PHE, payment for HCPCS code G0071 is set at the average of the national non-facility PFS payment rates for these 5 codes. Claims for G0071 will be paid at the CY 2021 rate of $13.53 and later reprocessed with the new rate of $24.76. The CY 2022 rate is $23.88. See Virtual Communication Services Frequently Asked Questions (PDF)
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Care Management Services
CCM services furnished on or after January 1, 2022, are paid at the average of the national non-facility PFS payment rate for CPT codes 99484, 99487, 99490, and 99491 (30 minutes or more of CCM services furnished by a physician or other qualified health care professional) and 99424 and 99426 (30 minutes or more of principal care management (PCM) services furnished by a physician or other qualified health care professional), using general care management HCPCS code G0511 which is updated annually based on the PFS amounts for these codes. The CY 2022 rate for G0511 is $79.25.
Psychiatric CoCM services furnished on or after January 1, 2019, are paid at the average of the national non-facility PFS payment rate for CPT codes 99492 (70 minutes or more of initial psychiatric CoCM services) and CPT code 99493 (60 minutes or more of subsequent psychiatric CoCM services) when psychiatric CoCM HCPCS code, G0512, is on an RHC claim, either alone or with other payable services. This rate is updated annually based on the PFS amounts for these codes. At least 70 minutes in the first calendar month, and at least 60 minutes in subsequent calendar months, of psychiatric CoCM services must have been furnished in order to bill for this service. The CY 2022 rate for G0512 is $151.23. - Revision of RHC Home Health Agency Shortage Requirement for Visiting Nursing Services During the COVID-19 PHE
RHCs can bill for visiting nursing services furnished by an RN or LPN to homebound individuals under a written plan of treatment in areas with a shortage of home health agencies (HHAs). Effective March 1, 2020 and for the duration of the COVID-19 PHE, the area typically served by the RHC is determined to have a shortage of home health agencies, and no request for this determination is required. RHCs must check the HIPAA Eligibility Transaction System (HETS) before providing visiting nurse services to ensure that the patient is not already under a home health plan of care.
Questions on RHC Issues?
Email RHC@cms.hhs.gov