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Proposed RHC Telehealth Legislation

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Due to COVID, we have seen how out-of-date telehealth regulations had been. It is essential the legislative changes be made to expand Telehealth statutes for Rural Health Clinics and FQHCs. As soon as the Public Health Emergency ends, Telehealth services and reimbursement will go back to the “old normal”.  We will no longer be able to provide services as the distant site. 

Please contact your US Senators and US Representatives.  Advocate for change!

H.R. 6792/S. 3998 – Improving Telehealth for Underserved Communities Act of 2020

  • allows RHCs/FQHCs to bill for telehealth through their normal reimbursement mechanisms for the duration of the Public Health Emergency.
  • raises the RHC cap to $92.03

Link To Senate Bill 3998

Link to HR 6792

H.R. 7187 – HEALTH Act of 2020

  • Permanently establishes RHCs/FQHCs as distant site providers paid through normal mechanisms (telehealth services would also count as visits)
  • Makes the payment methodology explicit.
  • Eliminates originating site requirements for telehealth services furnished by RHCs/FQHCS

Line-Item Billing for RHCs

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CMS has issued another update to the Rural Health Clinic Line-Item billing requirements being implemented on April 1, 2016.  Many Rural Health Clinics, independent and provider-based, will have to make significant software changes to deal with this.  The change is described in the MedLearn Matters MM9269, which was updated again today.

CMS has been making consistent updates to this policy.  The latest issue is that there is no accurate means to code a procedure only visit.  Rural Health Clinics have many questions about this change to line-item billing.  The main issue is the CMS has issued a Rural Health Clinic Qualifying Visit List.  The list only has evaluation and management codes, but no CPT codes for minor surgical procedures.  This means that the only way to bill a minor surgical procedure is with an inaccurate code.  CMS has not yet updated the Qualifying Visit list with minor surgical procedure.

Rural Health Clinics will no longer bundle many of their services.  Rural Health Clinics will need to list the service detail along with the relevant revenue code.  This will include the ability to separately list venipuncture, preventive services, injections, and other incident-to services.  This is a “sea-change” for most Rural Health Clinics.

This WILL go into effect – do not wait for it to be delayed.

“Effective April 1, 2016, RHCs, including RHCs exempt from electronic reporting under Section 424.32(d)(3), are required to report the appropriate HCPCS code for each service line along with the revenue code, and other required billing codes. Payment for RHC services will continue to be made under the All-Inclusive Rate (AIR) system when all of the program requirements are met. There is no change to the AIR system and payment methodology, including the “carve out” methodology for coinsurance calculation, due to this reporting requirement. ”

The full CMS guidance for Rural Health Clinics can be found here:  https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM9269.pdf

 

Incident-To Billing – WPS J5 Part B eNews:

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Incident-To Services – Supervising Provider Billing Instructions

In the office, among other criteria, incident-to services must be rendered by a qualified provider who is directly supervised. To meet supervision requirements for incident-to, the billing provider does not have to be physically present in the treatment room while the service is being provided, but must be present in the immediate office suite, for the entire duration of the service, to render assistance if needed.

If the billing physician is a solo practitioner, he/she must directly supervise the care. In a group practice, there may be situations when the provider responsible for the treatment plan is not the provider physically present in the office suite when the patient is seen in follow up. Thus, the supervising provider can be different than the ordering provider.

At this time, the supervising physician qualifier for Item 17 of the CMS-1500 (02-12) is not required for incident-to services. In the case of a service provided incident-to, when the person who ordered the service is not supervising, enter the National Provider Identifier (NPI) of the “supervising provider” in the lower unshaded portion of Item 24J. Read more at the following link:

http://www.wpsmedicare.com/j5macpartb/resources/provider_types/incident-services-supervising-provider-billing-instructions.shtml

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