FQHCs and RHCs now paid for Telehealth and Virtual Communications Services during COVID-19

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) passed by Congress on March 27, 2020 opened the door for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) to increase healthcare access to patients in rural and underserved areas by reimbursing for telehealth services to Medicare beneficiaries during the public health emergency (PHE). In addition, CMS has issued non-legislative policy changes and flexibility to address the increased need for remote services for Medicare beneficiaries in rural areas of the country. 

Read more about the telehealth and remote patient monitoring changes in the CARES Act here. 

On April 17, CMS released a guidance document clarifying the agency’s approach to reimbursement for FQHC and RHC telehealth and virtual communications services. The guidance describes the added flexibility for FQHC and RHC practitioners to provide synchronous audio/video telehealth visits delivered from any location – including the practitioner’s home – and to bill for those services as a “distant site” practitioner as opposed to receiving only the “originating site” facility fee available prior to the PHE waivers.  

CMS also expanded reimbursement for additional virtual communication services to include the new “online digital evaluation and management services” codes – otherwise known as “e-Visits” – introduced in the 2020 Medicare Physician Fee Schedule.  Unlike telehealth visits, e-Visits are not conducted using two-way live interactive audio video, but instead are non-face-to-face digital communications that may take place through secure patient portals. Virtual communications codes HCPCS G2010 (Remote Evaluation of Images) and HCPCS G2012 (Virtual Check-Ins) remain available for use by FQHCs and RHCs. 

FQHC/RHC Billing and Coding for Telehealth and Virtual Communications

Payment for telehealth services to FQHCs and RHCs is based on the volume-weighted average amount for all telehealth services on the Medicare Physician Fee Schedule, calculated at $92 for CY 2020. Claims submitted for telehealth services between January 27, 2020, and June 30, 2020 must include Modifier 95. These claims will be paid according to the Prospective Payment System (PPS) rate for FQHCs and at the All Inclusive Rate (AIR) for RHCs (currently $86.31) until payments are automatically re-processed in July. From July 1, 2020 until the end of the PHE or December 31, 2020, payments to RHCs and FQHCs should be submitted with code G2025 and will be paid at the $92 rate.

RHCs and FQHCs must waive the collection of co-payments from patients for telehealth services related to COVID-19 testing and must add the “CS” modifier on the service line in order for claims to be paid with the coinsurance applied. 

Payment for the following e-Visit codes will be made during the PHE:

• CPT code 99421 (5-10 minutes over a 7-day period)

• CPT code 99422 (11-20 minutes over a 7-day period)

• CPT code 99423 (21 minutes or more over a 7-day period)

The above codes can only be billed once every 7 days. Reimbursement for e-Visits, Remote Evaluation of Images (HCPCS G2010), and Virtual Check-Ins (HCPCS G2012) is payable by submitting HCPCS G0071, and is based on the average of these five Virtual Communications codes, calculated at $24.76 for CY 2020 – more than double the rate set forth in the 2020 Medicare Physician Fee Schedule. 

No Payment to FQHCs and RHCs for Remote Patient Monitoring

It is important to note that, to date, FQHCs and RHCs are NOT separately reimbursed for Remote Patient Monitoring services, including CPT Codes 99091, 99453, 99454, 99457, and 99458. RPM services are likely to play a critical role in diagnosing and managing COVID-19 patients, and we remain hopeful that CMS will issue further policy changes to allow payment to FQHCs and RHCs for remote patient monitoring. 

Beneficiary Consent

As always, beneficiary consent must be obtained for all patient services, including telehealth and virtual communications services. However, during the PHE, consent may be obtained at the time of service by auxiliary staff (employees or independent contractors) who are not licensed to provide care but who are under the general supervision of the billing RHC or FQHC practitioner – thereby freeing these practitioners from additional administrative burden.  This flexibility for obtaining patient consent is also important for facilitating other important programs for rural patients such as Chronic Care Management services.  

Visiting Nurse Services

RHCs and FQHCs can provide visiting nurse services to beneficiaries who are homebound in areas with a shortage of home health agencies. These services can be provided by an RN or LPN and must be the equivalent of a RHC or FQHC billable visit. CMS is assuming that the areas typically served by RHCs and FQHCs have a shortage of home health agencies, so facilities do not need to request a determination. However, the RHC or FQHC must check the HIPAA Eligibility Transaction System (HETS) before providing visiting nurse services to ensure that the patient is not already under a home health plan of care.

For more information about Medicare changes related to telehealth, remote patient monitoring, and other virtual communications services, please see our COVID Resource Page or contact us for more information. 

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