Billing and coding updates for this week
By Carol Hoppe, CPC, CCS-P, CPC-I
MedLucid Solutions

In addition to CMS’ decision to increase payments for audio-only telehealth visits reported elsewhere in today’s ISMA COVID-19 Update, there are some things happening with claims that you should be aware of, if you haven't noticed already.

The telehealth decision trees for Indiana and for FQHCs/RHC have been updated with some information about the CS modifier. The things highlighted in yellow in these decision trees are the important updates.

I am getting lots of calls about scheduling procedures and patients needing to be tested for COVID preoperatively as a hospital or surgery center requirement. First of all, Medicare does not typically cover preoperative clearance or testing other than for patients who have conditions that require it. They do not pay for hospital-required testing, so it's likely they will not cover the COVID test either.

However, CMS has not yet instructed the MACs on this, so we have no information to share yet. 

The pre-op visit that leads to the ordering of the test will very likely NOT be one in which you will add the CS modifier for waiver of cost-sharing because you shouldn't have signs or symptoms that would warrant payment by Medicare. More to come on that one...

The law waives cost-sharing under Medicare Part B for certain outpatient COVID-19 testing-related services. The CS modifier signals the Medicare to pay 100% for these services for dates of service on or after March 18, 2020. Claims submitted without the modifier may be resubmitted.

To learn more, refer to "Families First Coronavirus Response Act Waives Coinsurance and Deductibles for Additional COVID-19 Related Services" in the CMS MLN Connects Special Edition - Tuesday, April 7, 2020.

CIGNA requires Modifier CS to waive cost-sharing
There is a helpful chart that shows various scenarios and how to bill them correctly. I have not seen any other payer requiring the CS Modifier.

Apparently, the following self-funded plans are NOT covering telehealth visits for their members. In some cases, they are making the patient responsible and in others, the practice is held liable. 
Chrysler UAW
Anthem MediBlue Dual Advantage HMO
Team Ivy
State of Indiana
One America
NCI Building Systems (only MD Live covered)

Anthem does have their own telehealth service available for their members, so you will need to decide if you want to refer those self-funded plan patients elsewhere during the interim.

These are the latest updates from Indiana Medicaid. I have also received questions about secondary claims being denied for codes 99441-99443. I have sent an email to my IN Medicaid contact to ask about these denials. 
BT202049 – IHCP COVID-19 Response: Telemedicine FAQs as of April 21
BT202048 – IHCP COVID-19 Response: IHCP provides coding guidance for COVID-19

Listening to the Office Hours call with CMS on Tuesday, they stated that you will need to add the CG modifier when appropriate to get paid correctly prior to the new G code starting on July 1.  If you have already submitted claims without the CG modifier, CMS will issue further guidance regarding payments made at the RHC all-inclusive rate (AIR) or FQHC Prospective Payment System (PPS) rate rather than the $92.00 telehealth rate to be retroactively adjusted in July.