CMS waives telehealth restrictions for FQHC and RHC physicians

The Centers for Medicare & Medicaid Services (CMS) has released guidance allowing federally qualified health centers (FQHCs) and rural health clinics (RHCs) to provide distant site telehealth services.

FQHCs and RHCs were previously limited to serving as an originating site for telehealth services. But under new guidelines established by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, FQHCs and RHCs can serve as distant site providers of telehealth for the duration of the COVID-19 public health emergency. Telehealth services can be provided by any practitioner working for the FQHC or RHC within their scope of service and there are no restrictions on where the service is provided, meaning physicians or practitioners may provide the service from their homes.

CMS had previously waived the originating site requirement, and other telehealth restrictions, for physicians working outside FQHCs and RHCs. A full list of Medicare-covered telehealth services can be found here.

The payment rate for telehealth services furnished by an FQHC or RHC practitioner is $92, which is the average physician fee schedule amount for all services on the telehealth list, weighted by volume for those services. FQHCs and RHCs must use the -95 modifier for distant site services provided between Jan. 27, 2020, and June 30, 2020. FQHCs will be paid their Prospective Payment System (PPS) rate and RHCs will receive their all-inclusive rate (AIR). Claims will be automatically reprocessed in July, when the Medicare claims processing system is updated with the new rate.

For distant site services provided between July 1, 2020, and the end of the COVID-19 public health emergency, FQHCs and RHCs should use HCPCS code G2025 to identify the services furnished via telehealth. Claims with G2025 will be paid the $92 payment rate.

Costs for distant site telehealth services will not be used to determine the FQHC PPS rate or RHC AIR. However, they must be reported on the appropriate cost form.

Because CMS is waiving cost-sharing for services related to COVID-19 testing, FQHCs and RHCs should append the -CS modifier to claims related to COVID-19 testing. This modifier triggers the Medicare Administrative Contractors (MACs) to pay the full amount, including coinsurance. Coinsurance should not be collected from beneficiaries when cost-sharing is waived. MACs will automatically reprocess these claims beginning on July 1.

CMS also recently expanded the services that FQHCs and RHCs can provide through Virtual Communication Services using HCPCS code G0071. Beginning March 1, 2020, Virtual Communication Services include online digital evaluation and management services. These services are represented by CPT codes 99421-99423 under the Physician Fee Schedule. CMS updated the payment rate of HCPCS code G0071 to $24.76, which reflects the average of national non-facility amounts for HCPCS codes G2012 and G2010, and CPT codes 99421-99423. MACs will automatically reprocess claims with HCPCS code G0071 for services provided on or after March 1 to reflect the updated payment rate.

Practices are encouraged to reach out to their MACs for additional information. CMS’ full announcement can be found here.

— Erin Solis, Manager of Practice and Payment at the American Academy of Family Physicians