The Situation Report | March 6, 2023
The U.S. Centers for Medicare and Medicaid Services (CMS) has recently provided clarifications to our colleagues at the National Association for Home Care and Hospice (NAHC) regarding several issues concerning submitting claims with the new G-codes for telehealth encounters.
CMS has indicated that they do not want certified home health agencies (CHHAs) to submit a claim if the only services provided were via telecommunications technology. This position is in line with CMS’ policy that CHHAs are not to submit claims for payment periods without billable visits. While CMS recognizes that some data may be lost, they balanced that against the disruption and costs of changing a longstanding process. CMS will reconsider its position in the future after some experience with the data.
Additionally, CMS issued Change Request (CR) 12805 (https://www.cms.gov/files/document/mm12805-telehealth-home-health-services-new-g-codes.pdf) that updates the Medicare Claims Processing Manual and provides instructions to the Medicare Administrative Contractors (MACs) on reporting the new G codes for telehealth services on home health claims. In that CR under Business Requirement 12805.4 CMS states:
The contractor shall return to the provider claims containing HCPCS codes G0320, G0321 and G0322 if there is not another line item on the claim with the same revenue code and a G HCPCS code other than G0320, G0321 and G0322. Example: A claim with a line reporting revenue code 0551 and G0320 must also have a revenue code 055x line containing HCPCS G0299, G0300, G0162, G0493, G0494, G0495, or G0496.
The instructions required the MACs to include an edit that returned a claim to the provider if there was a G-code for a telehealth service without an onsite visit for that same discipline reported on the claim. Our colleagues at NAHC requested clarification from CMS for this edit since there is nothing in CMS’ policy or regulation that requires such claims reporting.
CMS reconsidered the edit and determined it was incorrect. The MACs have turned-off the edit. In the February 9, 2023, Medicare Learning Network Connects© newsletter, CMS noted the error and instructed providers to resubmit any impacted claims.
CMS will issue a CR in October that will permanently remove the edit from Medicare systems and revise the manual to be clearer that claims with no billable visits are not to be submitted (including claims with only telehealth services).