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Houston, We’ve Got a Problem

April 7, 2020

by Sean Weiss, Partner & VP of Compliance

Please Don’t Shoot the Messenger:

This was released today in a special release by CMS via MLN Matters. You must now use the CS Modifier to indicate cost sharing and in order to be paid 100% by Medicare.  For claims already submitted, you will not be able to do a corrected claim; you will have to file a new claim with the CS modifier. The concern now is whether or not it will get hung up as a duplicate claim. Again, this stuff is coming out every day and often every hour.

Please see what I have bold typed and underlined below:

Families First Coronavirus Response Act Waives Coinsurance and Deductibles for Additional COVID-19 Related Services

The Families First Coronavirus Response Act waives cost-sharing under Medicare Part B (coinsurance and deductible amounts) for Medicare patients for COVID-19 testing-related services. These services are medical visits for the HCPCS evaluation and management categories described below when an outpatient provider, physician, or other providers and suppliers that bill Medicare for Part B services orders or administers COVID-19 lab test U0001, U0002, or 87635.

Cost-sharing does not apply for COVID-19 testing-related services, which are medical visits that: are furnished between March 18, 2020 and the end of the Public Health Emergency (PHE); that result in an order for or administration of a COVID-19 test; are related to furnishing or administering such a test or to the evaluation of an individual for purposes of determining the need for such a test; and are in any of the following categories of HCPCS evaluation and management codes:

  • Office and other outpatient services
  • Hospital observation services
  • Emergency department services
  • Nursing facility services
  • Domiciliary, rest home, or custodial care services
  • Home services
  • Online digital evaluation and management services

Cost-sharing does not apply to the above medical visit services for which payment is made to:

  • Hospital Outpatient Departments paid under the Outpatient Prospective Payment System
  • Physicians and other professionals under the Physician Fee Schedule
  • Critical Access Hospitals (CAHs)
  • Rural Health Clinics (RHCs)
  • Federally Qualified Health Centers (FQHCs)

For services furnished on March 18, 2020, and through the end of the PHE, outpatient providers, physicians, and other providers and suppliers that bill Medicare for Part B services under these payment systems should use the CS modifier on applicable claim lines to identify the service as subject to the cost-sharing wavier for COVID-19 testing-related services and should NOT charge Medicare patients any co-insurance and/or deductible amounts for those services.

For professional claims, physicians and practitioners who did not initially submit claims with the CS modifier must notify their Medicare Administrative Contractor (MAC) and request to resubmit applicable claims with dates of service on or after 3/18/2020 with the CS modifier to get 100% payment. 

For institutional claims, providers, including hospitals, CAHs, RHCs, and FQHCs, who did not initially submit claims with the CS modifier must resubmit applicable claims submitted on or after 3/18/2020, with the CS modifier to visit lines to get 100% payment.

Additional CMS actions in response to COVID-19, are part of the ongoing White House Task Force efforts. To keep up with the important work the Task Force is doing in response to COVID-19, visit www.coronavirus.gov. For a complete and updated list of CMS actions, and other information specific to CMS, please visit the Current Emergencies Website.

 

General Disclaimer:  Advice or recommendations provided through this transmission have been given based on the review of the information provided.  DoctorsManagement, LLC or NAMAS cannot be held liable for any advice, findings, or recommendations given that could have had a variable answer based on additional information.

Sean M. Weiss is a Partner and serves as VP/Chief Compliance Officer for DoctorsManagement, LLC based in Knoxville, TN. DoctorsManagement, LLC services more than 20,000 clients nation-wide and has been in existence since 1956. Weiss serves as an Investigator and expert witness in Federal and State cases as well as an expert or lead in Administrative Law Judge Hearings. During his 25-year career, Weiss has engaged in more than 200 cases working with law firms and health systems across the country. Weiss serves as a third-party compliance and regulatory officer for more than a dozen health care organizations across the country of varying sizes. For more information on Sean M. Weiss or DoctorsManagement, LLC visit us online at www.doctors-management.com or contact us directly at 800.635.4040. You can also follow Sean on his biweekly Blog on LinkedIn (Sean M. Weiss “The Compliance Guy”) or at www.thecomplianceguyblog.com

What to do next…

  1. If you need help with an audit appeal or regulatory compliance concern, contact us at (800) 635-4040 or via email at info@drsmgmt.com.
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