Medicare Allows Institutional Billing for Some Outpatient Telehealth Services During the COVID-19 Pandemic

The Centers for Medicare & Medicaid Services (CMS) announced that institutional settings may now provide Medicare outpatient therapy services via telehealth and report them on institutional claims, such as the UB-04, if they are not included as part of a bundled institutional payment. This new development was released on May 28, 2020, on pages 70-71 of an updated CMS FAQ document [PDF] following ASHA and stakeholder advocacy seeking equitable expansion of Medicare telehealth services across settings.

Reporting Telehealth on Institutional Claims

According to CMS, outpatient telehealth services can be reported on institutional claims by applying modifier -95 to the appropriate service line. This applies only to services that can be billed separately from the institutional bundle, are paid under the Medicare Physician Fee Schedule (MPFS), and are included as an authorized service on the Medicare telehealth list. CMS specifically noted that speech-language pathology, physical therapy (PT), and occupational therapy (OT) telehealth services may be billed separately in this manner. However, audiology telehealth services were not addressed in this announcement. Outpatient audiology services provided in institutional settings are typically reimbursed as part of a bundled payment, such as the hospital outpatient prospective payment system (OPPS).

Setting Specific Guidance

CMS provides guidance for specific settings including applicable type of bill (TOB) codes and services, as follows.

• Hospital: Report hospital outpatient therapy services on TOB 12X or 13X. Hospital outpatient departments providing services via telecommunications technology as part of the bundled institutional payment, including audiology services paid under the OPPS, should continue to register the patient’s home as a temporary expansion site.
• Skilled Nursing Facility (SNF): Report PT, OT, and speech-language pathology services on TOB 22X or 23X only when the patient is not on a Part A stay.
• Critical Access Hospital (CAH): Report PT, OT, and speech-language pathology services on TOB 85X.
• Comprehensive Outpatient Rehabilitation Facility (CORF): Report ambulatory outpatient PT, OT, and speech-language pathology services on TOB 75X.
• Outpatient Rehabilitation Facility (ORF): Report ambulatory outpatient PT, OT, and speech-language pathology services on TOB 74X. 
• Home Health Agency (HHA): Report PT, OT, and speech-language pathology services on TOB 34X to patients in their homes only if those patients are not under a home health plan of care. 

Questions?

ASHA provides coding and billing guidance for Medicare telehealth services during the public health emergency. Contact reimbursement@asha.org for additional information.