On April 17, 2020, CMS issued MLN Matters Number: SE20016 identifying new payment for telehealth services provided by Rural Health Clinics (“RHCs”) and Federally Qualified Health Centers (“FQHCs”) as distant site providers. Prior to the Medicare expansion of telehealth coverage for services provided during the current COVID-19 Public Health Emergency (“PHE”), RHCs and FQHCs did not qualify as eligible distant site locations for purposes of Medicare reimbursement. The CARES Act, passed on March 27, 2020, reversed this position, authorizing both RHCs and FQHCs to serve as distant site telehealth locations, and required CMS to develop payment rates for these services similar to the national rates for comparable telehealth services under the Medicare Physician Fee Schedule. Per the MLN article:
“Distant site telehealth services can be furnished by any health care practitioner working for the RHC or the FQHC within their scope of practice. Practitioners can furnish distant site telehealth services from any location, including their home, during the time that they are working for the RHC or FQHC, and can furnish any telehealth service that is approved as a distant site telehealth service under the Physician Fee Schedule (PFS). A list of these is available at MLN Matters SE20016 Related CR N/A Page 2 of 4 https://www.cms.gov/files/zip/covid-19-telehealth-services-phe.zip.”
Distant site telehealth services will initially be paid at the RHC’s all-inclusive rate and the FQHC’s PPS rate; both entities must bill using Modifier 95 (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) on the claim. Beginning July 1, 2020, RHCs and FQHCs will bill using a specific G-code (G2025) that will pay $92. This expanded telehealth coverage for RHCs and FQHCs is only authorized during the COVID-19 PHE.
The MLN article also discusses the expansion of virtual communication services for RHCs and FQHCs. The MLN article can be found here.
If you have questions please contact:
- Chris Eades at (317) 977-1460 or ceades@hallrender.com;
- Regan Tankersley at (317) 977-1445 or rtankersley@hallrender.com;
- Scott Geboy at (414) 721-0451 or sgeboy@hallrender.com;
- Mike Batt at (317) 977-1417 or mbatt@hallrender.com;
- Your regular Hall Render attorney.
Hall Render’s attorneys and professionals continue to maintain the most up-to-date information and resources, which are available at our COVID-19 Resource page, through our 24/7 COVID‑19 Hotline at (317) 429-3900 or by contacting your regular Hall Render attorney.
Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.
