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New guidance on billing Medicare for professional telehealth during the public health emergency

April 02, 2020
Area(s) of Interest: Practice Management 


Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries, the Centers for Medicare and Medicaid Services (CMS) will now allow for more than 80 additional services to be furnished via telehealth. 

According to Noridian, when billing professional claims for non-traditional telehealth services with dates of services on or after March 1, 2020, and for the duration of the public health emergency, you should bill with the place of service (POS) equal to what it would have been in the absence of a public health emergency, along with a modifier 95, indicating that the service rendered was actually performed via telehealth. This is different than previous guidance to bill with a POS of 02. Claims billed with a POS of 02 will be paid at the facility rate.

Noridian has advised that claims for professional services already submitted with a POS of 02 can be corrected via the self-service Noridian Medicare Portal or by calling the telephone reopenings line at (855) 609-9960. This allows providers to correct clerical errors or omissions without having to resubmit or request a formal appeal.

As a reminder, CMS is not requiring the CR modifier on telehealth services. However, consistent with current rules for traditional telehealth services, there are two scenarios in which modifiers are required on Medicare telehealth professional claims:

  • Furnished as part of a federal telemedicine demonstration project in Alaska and Hawaii using asynchronous (store and forward) technology, use GQ modifier
  • Furnished for diagnosis and treatment of an acute stroke, use G0 modifier

Traditional Medicare telehealth services professional claims should reflect the designated POS code 02-Telehealth, to indicate the billed service was furnished as a professional telehealth service from a distant site. There is no change to the facility/non-facility payment differential applied based on POS. Claims submitted with POS code 02 will continue to pay at the facility rate.

For more information on telehealth billing during this public health emergency, see the California Medical Association Telehealth Overview.

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