Given the robust amount of content provided in the CCHP newsletter last week (July 16, 2024 edition), some readers may have missed a Change Request to the CMS Manual System issued by the Centers for Medicare and Medicaid Services (CMS) in June that went into effect July 8, 2024. Change Request 13582, Billing and Payment for Telehealth Services with Place of Service (POS) 10 was directed at the Medicare Administrative Contractors (MAC). MACs are entities that have a contract with CMS to process Medicare Part A and Part B claims for certain territories. When a claim is submitted to Medicare, it goes through the MAC covering the area where the claim is made. MACs receive instructions and information from CMS regarding relevant policies, including Change Request 13582, which is specific to the use of POS 10.
POS 10 is the place of service code used when the patient is located in their home when receiving services via telehealth. In the final Physician Fee Schedule (PFS) for 2024, CMS noted that for payable services billed with POS 10, the practitioner will be reimbursed at the non-facility rate (which pays an amount higher than the facility rate). This policy went into effect on January 1, 2024. However, as CCHP learned in early 2024, there were several MACs that were reimbursing providers at the lower facility rate if POS 10 was used on the claim. At the time, Noridian, a MAC for several states, flagged the issue through an alert, and reassured providers that CMS was aware of the issue and was working to resolve it. The issue appeared to be resolved in April 2024. Now, this recent Change Request has ensured the necessary changes are also specifically reflected in the CMS processing manual.
The new edition to the manual reads:
“Beginning in CY 2024, practitioners may receive either the facility or the non-facility payment rate for an otherwise eligible Medicare telehealth service, depending on whether the billing practitioner selects POS code 02 or POS code 10. As appropriate, POS 02 or POS 10 may be used and must be paired with the appropriate telehealth modifier (modifier 93 for audio-only and modifier 95 for audio/video). The payment rate for POS 02 is the facility payment rate (F); the payment rate for POS 10 us the non-facility rate (NF). The use of audio-only (93) or audio-video (95) does not change rate of payment only the POS code determines the non-facility or facility payment rate.” (Emphasis Added)
Although this change was not made until June/July, the policy applies to services that have been supplied as of January 1, 2024. Therefore, if a practitioner used POS 10 on their claim for a service provided on January 1, 2024 or later, they should receive the non-facility rate. Additionally, please note the bolded section of the new manual citation above regarding the use of modifiers 93 and 95 to ensure billing is completed as instructed. Previous guidance had seemed to limit the continued use of these modifiers to institutional provider claims only, therefore this is also an important clarification to highlight. For more information on the Change Request review the updated manual.
 Additionally, a reminder that the proposed CY 2025 Physician Fee Schedule (PFS) was released in early July. CCHP has created a fact sheet of the significant telehealth policy proposals as well as a video further discussing the proposals.
As a reminder, if you wish to provide comments on the CY 2025 proposals, you have until September 9, 2024 to do so.
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- RECENT CCHP VIDEO -Proposed CY 2025 PFSThe proposed CY 2025 Physician Fee Schedule (PFS) was released on July 10, 2024. The PFS contains policy changes proposed by CMS. Many have been anticipating these proposed rules due to the current December 31, 2024 end date of the COVID-19 telehealth policy waivers. The proposed 2025 PFS does provide some clarity around how CMS will address several telehealth policy issues in Medicare for next year, and it appears CMS has made attempts to mitigate any potential "cliff effect" should the December 31, 2024 expiration date hold. This video will cover the proposed 2025 PFS changes to telehealth policy in the Medicare program. For more information on the telehealth proposals specifically, view CCHP's Proposed 2025 PFS factsheet.
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CCHP knows that telehealth policy can be a complicated subject and from time to time questions about policies related to your specific situation may arise. You’re in luck…We’re here for you! Just submit your question via our easy to use contact us form, or send an email to info@cchpca.org
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