Question:  CMS is allowing PT/OT/SLP to perform services via telehealth. Do they bill on the UB 04 facility claim?

Answer:  Bill on the UB 04 if reported as hospital furnishes services.

Question: Are Registered Dieticians also able to bill on the UB?

Answer: If service is still furnished at the hospital or expansion site, the rules don’t change. No changes to who can provide services. The only change is to Hospitals Without Walls; they can be in any temporary expansion location of the hospital.  In order for the Hospital to bill, the home would have to be considered as an outpatient department of the hospital.

Question:  Does the expansion also include telehealth for PTA and COTA? And, if yes, is direct supervision still required?   Can these supervised visits be billed by the Therapist?

Answer: Yes, as long as requirements for supervision are met.  In a private practice setting, PT supervision can be met via virtual means.

Question: Should the 95 Modifier be attached to audio and visual when the codes are defined as audio only?

Answer: Based on instructions in newest list, they added both as audio only to telehealth services.

Question:   Can they use 2021 as a medical decision making standard for office outpatient visit codes?

Answer: The intention was to allow flexibility to use 2021 early for purposes of PHE, but will take back to confirm.

Question:    Can SNFs and HHAs bill for telehealth services furnished by therapists using the UB04 claim form?

Answer: When the patient is under Part A SNF stay, these services are bundled billed, and there is no change in the bundle billing.   For Home Health, that is a 30 day episode of care, and, if part of care, is bundled for that episode.   There has been no change in telehealth; really for therapists in private practice and in the hospital setting.   Other areas are still being considered.

Question: Does a hospital need to use the PO modifier for on-campus hospital outpatient department?

Answer: If in a home as an expansion site, they wouldn’t have to use the modifier.

Question: If doing a service in a temporary home, do you need to report the PN modifier, or would it be paid at full amount with the PO modifier?

Answer: Maintain the same modifier used normally.

Question: Please explain the difference between Q3014 and G0463 for billing audio visual services.

Answer: Depends on the service the patient is receiving.    If the hospital is supporting that telehealth service, the hospital could bill an originating site fee where the patient is registered as an outpatient of the hospital.   If the hospital is serving as a clinic, then bill accordingly.

Question: During an observation stay where COVID test may be part of workup, are they to attach CF modifier to all days of stay, or only the day of COVID testing for physician claims?

Answer:  For the hospital portion, CF modifier does mention hospital observation services as long as all other parts of the statutory requirements are met.   Not sure of the requirements in terms of how often the modifier is to show up.     For physician services within E/M management services, CF would apply to all days if evaluated to rule out COVID if all requirements are met.

Question: Can code G0463 be billed by pharmacist on a UB04 if provided in a provider based department?

Answer:   The regulation doesn’t change any rules about who can furnish a service.   Assuming that the service described by the HCPCS code is met, they describe ways in which a hospital can bill, as long as the patient is registered as a hospital outpatient and hospital is furnishing the service directly or remotely, they can bill for those services.   They would only expect services that CAN be done remotely to be billed for being done remotely.

Question: What about for Wound Care? Can this all be done remotely?

Answer: In terms of remote services, the staff does not have to be in the physical location.  For services that require physical presence, they would expect hospital staff to be physically present.  They have left it up to the hospital to determine if it can be done remotely or requires an in person visit.


Question: Each patient’s home has to be registered as a provider based clinic, correct?

Answer: If you are using the patient’s home as a temporary expansion location, they have outlined submitting those details to the regional office for use in that capacity.


Question:  How do you add someone’s home as a provider based department of the hospital?

Answer: The rule speaks to how to accomplish this as well as how to bill.   For HOPD not payable under OPPS, the regulation goes into detail about how this is handled.   The ability to make a patient’s home provider based to a hospital, is based on the waiver of provider based regulations at 42 CFR 413.65 through a blanket waiver.


Question:   Does policy of “it doesn’t count as telehealth if in the same location but not the same room” apply to all settings?

Answer:  Consistent across all settings, but that doesn’t mean that all settings would meet all conditions of payment for coverage.

For more information, guidance or assistance, please contact Advis’ experts online or call 708-478-7030.

Published: May 7, 2020