Q3014 - Telehealth originating site facility fee

HeatherDuboisHeatherDubois
in COVID-19

Hi All-

As our organization provides telephone & telemedicine encounters for services; we are considering using Q3014 for our provider based departments in addition to the professional E&M.  Anyone have any experience with this code?  If provider based are you applying this to a UB and the professional E&M to a 1500?  Thanks so much!

Comments

  • ronaldhirschronaldhirsch
    On one CMS call, they specifically said that only the physician professional fee is eligible for payment and there would be no facility fee payment for provider-based clinics. This was in regards, if I recall, to billing 99201-99215 codes with visits conducted via FaceTime or Skype, etc
  • HeatherDuboisHeatherDubois

    Thanks Dr. Hirsh; we do not expect to get reimbursed for this code.  However, we have an outside physician group making calls through hospital equipment, from the hospital campus, including using the patient portal; do we risk violating Stark law by not charging a facility charge for the service and allowing the physician group to charge and collect for the professional component?

  • ronaldhirschronaldhirsch
    Extraordinary times call for extraordinary measures. I would do what is right for the patients and providers and ensure there is no payment or reward to the physicians from your facility. But I am not a lawyer. Maybe a quick letter signed by docs stating they are being allowed use of your telehealth equipment in a national emergency and they do not consider this an inducement and the use will not affect their referral of patients for covered services. 
  • John.SettlemyerJohn.Settlemyer
    I agree with Ron.  Additionally, and more generally, the language of HR6074 is clear that Congress did not intend to relax any rules regarding billing for Q3014 and what qualifies as an originating site. Patients' homes do not qualify as an originating site [with the sole exception of Substance Use Disorder].  CMS documents could make this a little more clear!
  • CZNANIECCZNANIEC

    If the hospital facility is an originating site of the telehealth, and the distant site is not the same location, the facility may bill for the facility fee under RC0780 and HCPCS Q3014. The date of service is the discharge date of the encounter. See Q13 at the link below.

    https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf

    I am working now to finalize a summary document for telehealth coding and billing guidance across originating sites. Stay tuned. I hope to have something to share with this group later tomorrow (3/26)

  • CZNANIECCZNANIEC
    3/26/2020 - I have put together a guidance document to aid in the understanding of when an institutional provider can capture and bill for a facility fee. Please see attached.
  • 153366153366
    Our Physical Therapists want to do e-visits and bill for G0261-G0263.  I know it is paid from the PFS, but is it only billable on a 1500?
  • John.SettlemyerJohn.Settlemyer
    These codes will not be accepted/processed on a UB/Institutional - so by default yes only on a 1500.  Make sure to check APTA and your state-specific scope of practice for therapists as well.
  • CZNANIECCZNANIEC
    Medicaid providers are recognizing therapy for Telehealth. I would check with your specific state agency. See example in Louisiana https://www.louisianahealthconnect.com/newsroom/ldh-novel-coronavirus-disease--covid-19--provider-update--3-14-2.html
  • ronaldhirschronaldhirsch
    New guidance form CMS= for telehealth visits with FaceTime, etc, now use POS-11 and modifier -95 and you'll get full fee, unlike when POS 02 was used which paid facility rates 
  • CZNANIECCZNANIEC
    Updated COVID-19 guide - corrections on CAH TOB and modifier usage with facility claims.
  • stmsmithstmsmith
    Hi Caroline, can you elaborate a little more in general terms for me so I can explain this to the facility.   If a patient was seen in outpatient Wound Care or PT, and is now being seen at home, can you bill for both the professional and technical or just the professional?
  • HeatherDuboisHeatherDubois

    Hi All-

    I noticed the question regarding clam for PT/OT; United is allowing UB's with revenue code 780.

    https://www.uhcprovider.com/en/resource-library/news/Novel-Coronavirus-COVID-19/covid19-telehealth-services/covid19-telehealth-pt-ot-st.html

    I am hoping other payers will allow this to prevent credentialing issues.

    stmsmith we are interpreting the guidance that only facility or professional billing will be allowed for visits; because this continues to change for telehealth visits we are applying a facility statistical charge and a professional charge.  The facility statistical charge is being set up so it can be quickly updated to a billable charge if guidance changes.  There is still cost on the facility side (Med / Rec, Registration, etc) so hopefully payors will make consider allowing both. 

  • CZNANIECCZNANIEC
    Agree that from a CMS perspective it appears a technical fee is not allowed at this time if the facility and its staff (eg PT) is the distant site. However, states and payers may have different guidance. I like the idea of a facility statistic. We have seen that as guidance changes that CMS may retro dates. Many of us are awaiting clear guidance from CMS. The question is out there to them.
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