[TAO] FW: CMS and New POS Code for Telehealth and Distant Site Payment Policy
Catherine Britain
csbritain at gmail.com
Tue Nov 22 10:08:59 PST 2016
Greetings,
TAO's board chair, Jeff Caulley just sent this to me and I am passing it on
to you. If you provide telehealth services to Medicare patients please
read the information carefully as you will need to be in compliance by
Jauary 2017.
Best
Cathy
On Tue, Nov 22, 2016 at 9:13 AM, Caulley, Jeff <Jeffrey.Caulley at asante.org>
wrote:
> Hi Cathy J
>
> Just came across my email…
>
>
>
> Jeff
>
>
>
> *From:* Bartling, Toni
> *Sent:* Tuesday, November 22, 2016 8:52 AM
> *To:* Caulley, Jeff <Jeffrey.Caulley at asante.org>; Younkin, Katie <
> Katie.Younkin at asante.org>
> *Subject:* CMS and New POS Code for Telehealth and Distant Site Payment
> Policy
>
>
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> New POS Code for Telehealth and Distant Site Payment Policy
>
> *MLN Matters® Number: MM9726*
>
>
>
>
> * Related Change Request (CR) #: CR 9726 Related CR Release Date: August
> 12, 2016 Effective Date: January 1, 2017 - Under the Health Insurance
> Portability and Accountability Act of 1996 (HIPAA), the effective date for
> nonmedical data code sets, of which the POS code set is one, is the code
> set in effect the date the transaction is initiated. It is not date of
> service. Related CR Transmittal #: R3586CP Implementation Date: January 3,
> 2017*
>
> *Provider Types Affected *
>
> This MLN Matters® Article is intended for physicians, other practitioners,
> and suppliers submitting claims to Medicare Administrative Contractors
> (MACs) for services provided to Medicare beneficiaries.
>
> *Provider Action Needed *
>
> CR 9726 updates the Place of Service (POS) code set by creating a new code
> (POS 02) for Telehealth services, effective January 1, 2017. You should
> ensure that your billing staffs are aware of this new POS code.
>
> *Background *
>
> As an entity covered under the Health Insurance Portability and
> Accountability Act of 1996 (HIPAA), Medicare must comply with standards,
> and their implementation guides, adopted by regulation under this statute.
> The currently adopted professional implementation guide for the ASC X12N
> 837 standard requires that each electronic claim transaction include a
> Place of Service (POS) code from the POS code set that the Centers for
> Medicare & Medicaid Services (CMS) maintains. The POS code set provides
> setting information necessary to appropriately pay Medicare and Medicaid
> claims.
>
> As a payer, Medicare must be able to recognize, as valid, any valid code
> from the POS code set that appears on the HIPAA standard claim transaction.
> Further, unless prohibited by national policy to the contrary, Medicare not
> only recognizes such codes, but also adjudicates claims that contain these
> codes.
>
> At times, Medicaid has had a greater need for code specificity than has
> Medicare; and many of the new codes, over the past few years, have been
> developed to meet Medicaid's needs. While Medicare does not always need
> this greater specificity in order to appropriately pay claims, it
> nevertheless adjudicates claims with the new codes to ease coordination of
> benefits and to give Medicaid and other payers the setting information they
> require.
>
> Effective January 1, 2017, CMS is creating a new POS code 02 for use by
> the physician or practitioner furnishing telehealth services from a distant
> site. CR 9726 updates the current POS code set by adding this new code (POS
> 02: Telehealth), with a descriptor of "The location where health services
> and health related services are provided or received, through
> telecommunication technology."
>
> Medicare will pay for these services using the Medicare Physician Fee
> Schedule (MPFS), including the use of the MPFS facility rate for Method II
> Critical Access Hospitals billing on type of bill 85x. This Telehealth POS
> code would not apply to originating site facilities billing a facility fee.
>
> *Remember that under HIPAA, the effective date for nonmedical data code
> sets, of which the POS code set is one, is the code set in effect the date
> the transaction is initiated. It is not date of service. *
>
> Modifiers GT (via interactive audio and video telecommunications systems)
> and GQ (via an asynchronous telecommunications system) are still required
> when billing for Medicare Telehealth services. If you bill for Telehealth
> services with POS code 02, but without the GT or GQ modifier, your MAC will
> deny the service with the following messages:
>
> · Group Code CO
>
> · Claim Adjustment Reason Code (CARC) 4 (The procedure code is
> inconsistent with the modifier used or a required modifier is missing.
> Note: Refer to the 835 Healthcare Policy Identification Segment (loop 2110
> Service Payment Information REF), if present)
>
> · Remittance Advice Remarks Code (RARC) MA130 (Your claim
> contains incomplete and/or invalid information, and no appeal rights are
> afforded because the claim is unprocessable. Please submit a new claim with
> the complete/correct information)
>
> Conversely, if you bill for Telehealth services with modifiers GT or GQ,
> but without POS code 02, your MAC will deny the service with the following
> messages:
>
> · Group Code CO
>
> · CARC 5 (The procedure code/bill type is inconsistent with the
> place of service. Note: Refer to the 835 Healthcare Policy Identification
> Segment (loop 2110 Service Payment Information REF), if present)
>
> · RARC M77 (Missing/incomplete/invalid/inappropriate place of
> service)
>
> *Additional Information *
>
> The official instruction, CR9726, issued to your MAC regarding this change
> is available at https://www.cms.gov/Regulations-and-Guidance/
> Guidance/Transmittals/downloads/R3586CP.pdf [image: This link will take
> you to an external website.].
>
> Last Updated Nov 21, 2016
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--
Catherine S. Britain, Executive Director
Telehealth Alliance of Oregon
csbritain at gmail.com
541-910-7366
www.ortelehealth.org
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