Telehealth under the COVID-19 PHE.
The patient does not have to go to an originating site and can take part in telehealth from their home.
As a result, CMS does not have to pay a facility fee to an originating site. The provider is incurring practice expenses in delivering the telehealth, so CMS is paying providers for practice expense in the fee schedule when a provider, who usually practices in an office, provides telehealth services during the COVID-19 PHE.
If POS 02 is used, the provider will not be paid for practice expense because the POS 02 triggers the facility provider fee schedule. CMS says in the April 6 IFC that providers who usually provide services in the office should use POS 11 for their telehealth services during the COVID-19 PHE. But the MAC needs to know that the service is telehealth. Without using POS 02 and using POS 11, however, the MAC cannot distinguish between an in-person service and a telehealth encounter. That is why CMS has indicated that modifier95 has to be added to the CPT/HCPCS Level II codes provided during the telehealth encounter.
This will ensure the office, non-facility provider fee schedule will be paid, including the practice expense, and the MAC will know that the services were provided via telehealth.
The patient does not have to go to an originating site and can take part in telehealth from their home.
As a result, CMS does not have to pay a facility fee to an originating site. The provider is incurring practice expenses in delivering the telehealth, so CMS is paying providers for practice expense in the fee schedule when a provider, who usually practices in an office, provides telehealth services during the COVID-19 PHE.
If POS 02 is used, the provider will not be paid for practice expense because the POS 02 triggers the facility provider fee schedule. CMS says in the April 6 IFC that providers who usually provide services in the office should use POS 11 for their telehealth services during the COVID-19 PHE. But the MAC needs to know that the service is telehealth. Without using POS 02 and using POS 11, however, the MAC cannot distinguish between an in-person service and a telehealth encounter. That is why CMS has indicated that modifier95 has to be added to the CPT/HCPCS Level II codes provided during the telehealth encounter.
This will ensure the office, non-facility provider fee schedule will be paid, including the practice expense, and the MAC will know that the services were provided via telehealth.
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