Home Health & Hospice Week

CMS issued telehealth coding details internally back in July.

Remember that final rule that came out some days back with a requirement to use new telehealth G codes? Medicare is already serving those up.

Reminder: In its 2023 home health final rule, the Centers for Medicare & Medicaid Services finalized a proposal for home health agencies to use three new G codes to report telehealth services (see HHHW, Vol. XXXI, No. 39-40). CMS implemented the change despite advice from industry experts that CMS should use a modifier for reporting telehealth services instead of brand-new codes, among other suggestions.

Now a new transmittal shows one reason CMS may have been so eager to adopt the proposal without changes. In July 21 Change Request 12805, which was kept under wraps until Nov. 2, CMS “create[s] new G-codes for reporting home health services furnished by telehealth and … revise[s] Original Medicare systems to process them without affecting payment to the home health agency,” the transmittal says.

As the final rule states, HHAs will start “voluntary reporting of the new G-codes beginning with HH periods of care that start on or after January 1, 2023,” according to the CR. HHAs will commence “mandatory reporting beginning with HH periods of care that start on or after July 1, 2023,” the transmittal indicates.

“Collecting data on the use of telecommunications technology on home health claims will allow CMS to analyze the characteristics of the beneficiaries utilizing services furnished remotely, and will give us a broader understanding of the social determinants that affect who benefits most from these services, including what barriers may potentially exist for certain subsets of beneficiaries,” the agency says in the CR.

Don’t Miss These Instructions

“HHAs shall submit the use of telecommunications technology when furnishing home health services, on the home health claim via three G-codes,” CMS details in the transmittal:

• G0320: home health services furnished using synchronous telemedicine rendered via a real-time twoway audio and video telecommunications system. (Short Descriptor: G0320: two-way audio and video HHS)
• G0321: home health services furnished using synchronous telemedicine rendered via telephone or other real-time interactive audio-only telecommunications system. (Short Descriptor: G0321: audio-only HHS)
• G0322: the collection of physiologic data digitally stored and/or transmitted by the patient to the home health agency (i.e., remote patient monitoring). (Short Descriptor: G0322: Home H physio data collec tr).
• CMS offers a couple of clarifications about reporting:

1. “The use of remote patient monitoring that spans a number of days shall be reported as a single line item reporting the beginning date of monitoring and the number of days of monitoring in the unit’s field,” CMS instructs in the CR.
2. “HHAs shall submit services furnished via telecommunications technology in line item detail and each service must be reported as a separate line under the appropriate revenue code for each discipline furnishing the service,” CMS details.

Tip: “Any telehealth or remote patient monitoring that you provide to the patient will need to be reflected on the claim, even though it will not impact your payments,” advises consultant Melinda Gaboury with Healthcare Provider Solutions in Nashville, Tennessee. “At this point, it will simply provide additional information to hopefully set future rates for telehealth reimbursement,” Gaboury notes in her Monday Minute with Melinda vlog.

On The Bright Side

The new G codes will have some advantages, believes billing expert M. Aaron Little with FORVIS in Springfield, Missouri. “I’m actually happy it wasn’t just a modifier code that CMS chose to use for capturing the services,” Little tells AAPC. “In very general terms, EMR vendors are more accustomed and better prepared to handle new HCPCS codes than modifiers,” he says.

However: “I do wonder whether using HCPCS codes for these services will fully accomplish CMS’ goal of data collection and analysis,” Little muses. “The HCPCS codes will be billed on claims with the corresponding discipline-specific revenue code, which will allow the claims to distinguish in-person visits from telehealth services. However, for cost report purposes, I’m wondering how the telehealth services will be reported,” he notes.

The way PS&R reports are structured make it unclear whether in-person versus telehealth visits will be readily distin­guishable, Little says. “How the tele visits will be matched to tele costs on the cost report is not something I’ve seen be addressed yet,” he notes. “Not to say it’s been overlooked by CMS, but maybe they just haven’t come up yet with that solution and such instruction would be issued in the future.”

Bottom line: “Thanks CMS for the new billing requirements, but please don’t forget to give us guidance on how to handle these new billable services on the cost report,” Little says.

Note: The 20-page CR is at www.cms.gov/files/document/r11502cp.pdf.