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Telehealth Guidance for RHCs and FQHCs

On Friday, April 17, 2020, CMS finally released guidance for RHCs and FQHCs in terms of telehealth distant site services. Below is a snapshot of the information released in the MLN Matters Article. A link to the full release can be found here.

  • The guidance from CMS will apply to claims dating back to January 27, 2020. Any held claims may now be submitted for payment.
  • CMS has set the payment rate for distant site services for RHCs and FQHCs at $92.00. This is based on the average payment amount for all telehealth services on CMS’s approved telehealth list with adjustments made for volume of those services reported under the physician fee schedule. The complete list of approved telehealth services can be downloaded here,
  • For those dates of service beginning January 27, 2020, until June 30, 2020, RHCs and FQHCs should report the appropriate CPT code for the service provided, and include modifier “95” to indicate that the service took place via telehealth rather than in-person.
    • RHCs should also still report modifier “CG” on the appropriate claim line to indicate the qualifying service. Additional guidance, pending.
  • Until July 1, 2020, CMS will pay for telehealth distant site services at the all-inclusive rate (AIR) for RHCs, or according to the prospective payment system (PPS) for FQHCs.
    • Once the claims processing system has been updated, CMS will automatically reprocess those claims at the newly established payment rate of $92.00.
    • For clinics with a rate below $92.00, CMS will make an additional payment to make up for the payment difference between your rate and the $92.00 telehealth distant site rate.
    • For those clinics with a rate above $92.00, CMS will recoup the appropriate amount.
  • For those telehealth distant site services taking place on or after July 1, 2020, CMS has established a new G code, G2025, which is specific to RHCs/FQHCs. This new G code should be billed for all telehealth distant site services provided on or after this date. The reimbursement rate for G2025 will be set at the newly established rate of $92.00.
    • This will remain in effect until the end of the COVID-19 public health emergency.
  • CMS also confirmed that any cost associated with the delivery of telehealth services should be accounted for on the cost report, but will be included in the “non-reimbursable costs” section of the cost report for RHCs and FQHCs. In doing so, costs associated with the delivery of telehealth services will not be taken into account when calculating the clinic’s cost-per-visit amount.

Please visit our FAQs for RHCs and FQHCs during COVID-19 article for more information on telehealth services and other provisions impacting RHCs and FQHCs during the public health emergency.

Please visit our Coronavirus Resources & Information for additional guidance on related items. 

If you have further questions, please contact one of our RHC and FQHC team members.

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