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