CMS Issues Guidance on Place of Service for Telemedicine Claims

In an Interim Final Rule published yesterday in a pre-publication of the Federal Register, CMS has noted that – for the duration of this emergency – providers who are performing telemedicine visits should bill the place of service (POS) as you would if the service was performed in person.  That means for most telemedicine billing in ophthalmology, you are advised by CMS to use the Place-of-Service (POS) office code “11” instead of “02” for Telehealth.  CMS also advised providers to use modifier 95 for live audio-video visits coded as 992xx exam codes.  Previously, CMS had noted that no modifiers were required.

CMS says it is using the modifier to track telemedicine as opposed to the POS code.  Both of these changes are retroactive to March 1, 2020.  This also allows payment for telemedicine at normal office (aka “non-facility”) rates instead of the much lower “facility” rates.

They noted:

“ …we believe that, as more telehealth services are furnished to patients wherever they are located … services furnished through telehealth should be reflected in the payment … as if they furnished the services in person, and to assign the payment rate that ordinarily would have been paid [as if] … furnished in person … To implement this change on an interim basis, we are instructing physicians and practitioners who bill for Medicare telehealth services to report the POS code that would have been reported had the service been furnished in person. This will allow our systems to make appropriate payment for services furnished via Medicare telehealth …”

They further noted:

 “… Because we currently use the POS code on the claim to identify Medicare telehealth services, we are finalizing on an interim basis the use of the CPT telehealth modifier, modifier 95, which should be applied to claim lines that describe services furnished via telehealth …”

We are happy to assist you with claims issues and other topics related to eye care during this public health emergency.  Check back often for updated News Items related to billing, documentation, and operations related to your practices during COVID-19.  Stay safe.

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