Medicare Compliance & Reimbursement

Question: With all the COVID-19 billing updates coming down the pike, our practice is confused about the CS modifier? What exactly is it for and how should we use it?

Ohio Subscriber

Answer: In coordination with the Families First Coronavirus Response Act (FFCRA), the Centers for Medicare & Medicaid Services (CMS) is waiving cost-sharing for patients that meet a specific set of COVID-19 testing criteria during E/M visits.

Then: “Previously, CMS made available the CS modifier for the gulf oil spill in 2010,” but it is now repurposing it for COVID-19, agency guidance explains.

Now: As part of the implementation of the FFCRA and the CARES Act, CMS is waiving “cost-sharing under Medicare Part B (coinsurance and deductible amounts) for Medicare patients for COVID-19 testing-related services,” notes an MLN Matters release from April 7. This means that for COVID-19 testing-related services, cost-sharing in the form of co-pays and deductibles is waived when you append the CS modifier (Cost-sharing for specified covid-19 testing-related services that result in an order for or administration of a covid-19 test) to your E/M claims.

Bonus: Physicians will receive 100 percent of payment for modifier CS-appended claims.

In addition to appending the modifier to your respective claim, “you should NOT charge Medicare patients any co-insurance and/or deductible amounts for those services,” clarifies CMS in an April 10 MLN Matters update.

According to CMS guidance, the following guidelines pertain to E/M services that led to the administration or ordering of COVID-19 lab tests by an outpatient provider, physician, or “other providers and suppliers billing under Medicare Part B.” This means that, in order to waive cost-sharing, the E/M visit must result in one of the following COVID-19 lab tests being ordered or performed:

• U0001 (Cdc 2019 novel coronavirus (2019-ncov) real-time rt-pcr diagnostic panel)
• U0002 (2019-ncov coronavirus, sars-cov- 2/2019-ncov (covid-19), any technique, multiple types or subtypes (includes all targets), non-cdc)
• 87635 (Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique)

For the aforementioned services that are billed to their respective payment systems, CMS explains that you should append modifier CS “on applicable claim lines to identify the service as subject to the cost-sharing waiver for COVID-19 testing-related services,” the agency adds.

Tip: Providers may also retroactively resubmit applicable professional claims with modifier CS from March 18 and beyond so long as they contact their Medicare carrier beforehand. Institutional claims may also be resubmitted with modifier CS appended to receive 100 percent payment.