Medical Billing and Coding Healthcare Blog

The Centers for Medicare & Medicaid Services (CMS) has recently published a revised fact sheet on telehealth services.

The fact sheet provides information about originating sites; distant site practitioners; telehealth services; and billing and payment for professional services furnished via telehealth and the originating site facility fee.

Here is some important background information on telehealth services.

Telehealth Services Overview

Medicare pays for a limited number of Part B services furnished by a physician or practitioner to an eligible beneficiary via a telecommunications system. For eligible telehealth services, the use of a telecommunications system substitutes for an in-person encounter.

An originating site is the location of an eligible Medicare beneficiary at the time the service furnished via a telecommunications system occurs. Medicare beneficiaries are eligible for telehealth services only if they are presented from an originating site located in:

  • A rural health professional shortage area (HPSA) located either outside of a metropolitan statistical area (MSA) or in a rural census tract; or
  • A county outside of a MSA.

Originating sites authorized by law are:

  • offices of physicians or practitioners;
  • hospitals;
  • critical access hospitals (CAH);
  • rural health clinics;
  • federally qualified health centers;
  • hospital-based or CAH-based renal dialysis centers (including satellites);
  • skilled nursing facilities; and
  • community mental health centers (CMHCs).

Practitioners at the distant site who may furnish and receive payment for covered telehealth services (subject to state law) are:

  • physicians;
  • nurse practitioners (NPs);
  • physician assistants (PAs);
  • nurse-midwives;
  • clinical nurse specialists (CNSs);
  • certified registered nurse anesthetists;
  • registered dietitians or nutrition professionals; and clinical psychologists (CPs) and clinical social workers (CSWs). Note: CPs and CSWs cannot bill for psychiatric diagnostic interview examinations with medical services or medical evaluation and management services under Medicare. These practitioners may not bill or receive payment for CPT codes 90792, 90833, 90836, and 90838.

As a condition of payment, physicians or practitioners at the distant site must use an interactive audio and video telecommunications system that permits real-time communication between the distant site and the beneficiary at the originating site.

If your organization requires assistance with billing for telehealth services, contact medical billing company PGM Billing. PGM is a leading integrated physician billing, practice management and electronic medical record service that provides highly efficient medical claims processing that helps healthcare providers improve their collections and cash flow, while gaining valuable insight into their organization's performance.

The Centers for Medicare & Medicaid Services (CMS) has published a final rule on reporting and returning self-identified Medicare overpayments.

The rule is specifically for Medicare parts A and B healthcare providers and suppliers. A separate final rule was published in May 2014 that addressed Medicare Parts C and D overpayments.

The major provisions for providers in the new rule are as follows:

  • An overpayment must be reported and returned by the later of the date which is 60 days after the date on which the overpayment was identified or the date any corresponding cost report is due (if applicable).  
  • An overpayment is "identified" if the person has actual knowledge of the existence of the overpayment or acts in reckless disregard or deliberate ignorance of the overpayment.
  • Overpayments must be reported and returned only if a person identifies the overpayment within six years of the date the overpayment was received. Note: The original overpayments rule required physicians to look back through 10 years of claims to make sure Medicare had not overpaid them
  • Providers must use an applicable claims adjustment, credit balance, self- reported refund or another appropriate process to satisfy the obligation to report and return overpayments.
  • If a provider has reported a self-identified overpayment to either the self-referral disclosure protocol managed by CMS or the self-disclosure protocol managed by the Office of the Inspector General, the provider or supplier is considered to be in compliance with the provisions of this rule as long as they are actively engaged in the respective protocol.

Access the final rule here.

Providers that fail to report and return an overpayment could face potential False Claims Act liability, Civil Monetary Penalties Law liability and exclusion from federal healthcare programs. Reduce your practice's risk of getting sued by the government due to missed overpayments by outsourcing your billing to Physicians Group Management (PGM), a leading medical practice management company. For 35 years, PGM has provided physicians with a wide range of innovative solutions that help practices run more efficiently, including a robust medical billing service backed by a team of experienced, certified coders and billers.      

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