It also details the proper modifiers for telehealth and the revenue code for telemedicine institutional claims. The guide goes on to cover how to bill for virtual healthcare that is not considered Telehealth by CMS (Centers for Medicare and Medicaid Services): Remote Evaluation and Virtual Check-in, Remote Physiologic Monitoring, eConsult, eVisit, and mHealth.
But, what are the requirements for billing CMS for telemental health?
First, be accurate about the Service Provided. If it is not defined as Telehealth by CMS then this changes the place of service code and other billing requirements.
Then check that the location of the client is an approved originating site such as a community mental health clinic or, in some cases, the client’s home. HRSA provides a tool for that Here (https://data.hrsa.gov/tools/medicare/telehealth).
You need to provide the correct place of service. The method for doing this has changed over time. CMS provides a POS (Place of Service) code list Here (https://www.cms.gov/Medicare/Coding/place-of-service-codes/Place_of_Service_Code_Set.html).
One must also be an approved provider for CMS reimbursement. For TeleMental Health this currently excludes counselors, marriage and family therapists, and other behavioral health license types. Clinical psychologists and clinical social workers, however, are included as approved providers.
What address do I place in the 1500 form if I work from home?
The guide shares that “CMS indicated that ‘...practitioners must use the address where they typically practice in Box 32. If they work part of the time out of a clinic and part of the time out of their home, they may use the clinic address. If they work out of their home 100% of the time, as some providers do, they must use their home address.’” (page 5). The guide lists an exception for providers who have given their enrollment rights to another facility or group.
The CCHP guide tells us that “For synchronous telehealth services in Medicare, a POS 02 must go on the bill.”
Use the CPT code proper to the psychotherapy service provided. Also, as we indicate in a previous article titled Medicare Reimbursement for Telehealth, “Now that the place of service 02 is used to designate telehealth the GT or 95 modifiers are not needed (with the exception CAH Method II billing).” The CCHP guide does list modifiers required for virtual care that are not labeled as Telehealth by CMS.
Can I bill Medicare for psychotherapy services provided to a client who is in their home at the time of service?
According to the guide, Medicare has very strict rules for what constitutes an approved originating site. State-run Medicaid programs often expand the list of approved originating sites to sometimes include the client’s home. For Medicare, however, clients receiving treatment for substance abuse and co-occurring disorders are (among other services) able to receive treatment at home, with the home being an approved originating site. However, there are special requirements. The CMS website states:
“Beginning July 1, 2019, the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act removes the originating site geographic conditions and adds an individual’s home (emphasis added) as a permissible originating telehealth services site for treatment of a substance use disorder or a co-occurring mental health disorder." (Page 3, https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/TelehealthSrvcsfctsht.pdf, accessed February 2020)
In conclusion, it is important to realize that the billing requirements often change to reflect the services approved as Telehealth by CMS. So be sure to check authoritative guides from CMS themselves and helpful guides like the one published by CCHP. When in doubt, consult with a professional biller you trust to help make sure you get it right.
If you haven’t done so yet, check out our interview with an Experienced Mental Health Billing Consultant.