[UPDATED] CMS Clarifies Institutional Providers May Bill E-visits, Virtual Check-ins, Telephone Assessments

[UPDATED] CMS Clarifies Institutional Providers May Bill E-visits, Virtual Check-ins, Telephone Assessments

On Friday, May 15, 2020, CMS released Transmittal 10139 which updated the Therapy Code List to include the HCPCS and CPT codes representing e-visits, virtual check-ins, and telephone assessments as “sometimes therapy” codes for the duration of the COVID-19 public health emergency.

With these documents, therapists providing services in institutional settings such as hospital outpatient departments, rehab agencies, and skilled nursing facilities, finally have a bit of good news: They can provide these services and bill them to Medicare Part B. In the MLN article, CMS states, “When provided by therapists in private practice or therapists in institutional providers of therapy services…” the communication technology-based services (CTBS) are provided under a PT, OT, or SLP plan of care and require the GP, GO, or GN modifier.

The effective date of this change is March 1, 2020. On Tuesday, May 26, CMS released Transmittal 10161 and an updated version of MLN article 11791 which changes the implementation date to June 16, 2020, for MACs and July 6, 2020, for FISS. The implementation date reflects the date the MACs and FISS must have their systems updated to accept the CTBS CPT/HCPCS codes with the GP, GO, and GN modifiers. Although retroactive to March 1st, appending the GP/GO/GN modifier may result in a claim rejection if the payer’s system is not yet updated. So, a bit of good news, but with a twist, at least until June 16th.

For more information and a list of the specific CPT/HCPCS codes included, review the transmittal and the MLN article.

Holly Hester

Holly Hester is Casamba’s Senior Vice President of Compliance & Education, as well as the Compliance Officer. She provides regulatory guidance and interpretation, clinical programming and content development, education and training steerage, and compliance support for the company. As a physical therapist for more than 20 years, Holly has multi-venue clinical and management experience, giving her a unique perspective on the integration of compliance and training with therapy service delivery and clinical practice.
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