Last week, CCHP featured in its In Focus newsletter updates made to the Telehealth Services Medicare Learning Network (MLN) Fact Sheet by the Centers for Medicare and Medicaid Services (CMS). While much of the guidance remains consistent with the previous version, the document offers crucial updates, incorporating policies from the Consolidated Appropriations Act, 2023 (CAA 2023) and CY 2024 Physician Fee Schedule (PFS) Final Rule. Notably, the factsheet addresses specific payment rules and coding requirements, which often present complexities for providers. Highlighted updates include information on telehealth modifiers, Place of Service (POS) codes, and reimbursement guidelines for hospitals and non-hospital-based providers. Additionally, the factsheet introduces new codes added to the Medicare telehealth services list and covers various policy additions from CAA 2023/CY 2024 PFS, such as continuing payment for telehealth services in rural health clinics and federally qualified health centers.
In CCHP’s coverage last week, we also highlighted a coding and payment issue not addressed in the factsheet but that has been affecting many providers billing telehealth services since 2024 began. The issue involves a glitch in CMS’ system that has been causing providers to receive the facility rate for Place of Service Code 10 (telehealth to the patient’s home), as opposed to the higher non-facility rate, which CMS had indicated would be provided for POS code 10 in the CY 2024 PFS. Recently, Noridian, a Medicare Administrative Contractor (MAC) for several states, flagged the issue through an alert as well. This unexpected development has caught the attention of healthcare providers and administrators, as CCHP has received several inquiries into the matter. CMS has been made aware of this issue and has assured stakeholders that they are actively investigating the matter. While the investigation is ongoing, CMS has stated that no immediate action is required from providers or facilities.
For further details and resources on Medicare telehealth billing, including billing and coding information for Medicare Fee-for-Service claims and telehealth policy changes post-COVID-19, please refer to the new telehealth MLN Telehealth Factsheet and CCHP’s In Focus newsletter for the highlights. As we continue forward, stay tuned to CCHP for ongoing updates on Medicare telehealth billing practices.