Wiki Hospital Telehealth Billing-Q3014?

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bucko

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The more we read the more we are confused about what to code for outpatient hospital telehealth services. Should we use Q3014 or the E&M service? We know how the physician side should bill but cannot locate any clear documentation for the outpatient hospital established patient telehealth coding.
 
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Basically, billing Q3014 hasn't changed. It is used ONLY by originating sites. An originating site is the physical location of the patient. It is to reimburse the facility expense of having the patient located at your site while they are video communicating with a provider located elsewhere.
Right now, for the vast majority of practices billing for telehealth during the emergency, the patient is located at home. There is no originating site. The provider bills E/M (or other applicable codes based on specialty/services), with modifier -95 and POS that would have been if not for the emergency.
I hope that helps better explain Q3014.
 
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However, in the 5/6/20 CMS New Alert Fact Sheet, there is this statement where is says 'if the beneficiary's home....is considered to be a provider based department of the hospital and the beneficiary is registered as an outpatient of the hospital for purposes of receiving telehealth services billed by the physician or proactitioner, the hospital may bill under PFS for the originating site facility fee associated with the telehealth service.'
Excerpt below. This leads us to believe we can bill Q3014.


Telehealth

  • •Hospital Outpatient Services Accompanying Professional Services Furnished ViaTelehealth: When a physician or nonphysician practitioner who typically furnishesprofessional services in the hospital outpatient department furnishes telehealth servicesduring the COVID-19 PHE, they bill with a hospital outpatient place of service since thatis likely where the services would have been furnished if not for the COVID-19 PHE. Thephysician or practitioner is paid for the service under the PFS at the facility rate, whichdoes not include payment for resources such as clinical staff, supplies, or officeoverhead since those things are usually supplied by the hospital outpatient department.During the COVID-19 PHE, if the beneficiary’s home or temporary expansion site isconsidered to be a provider-based department of the hospital, and the beneficiary isregistered as an outpatient of the hospital for purposes of receiving telehealth servicesbilled by the physician or practitioner, the hospital may bill under the PFS for theoriginating site facility fee associated with the telehealth service.
 
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So in your case, clinician typically sees patients in person at outpatient hospital location POS 22. During the emergency, the patient is still going to the outpatient hospital (or temporary expansion site considered to be provider based dept of hosp) for the purposes of receiving telehealth.
If so, then provider bills E/M -95 POS 22, and hospital facility can bill for Q3014 to cover their expense of having the patient physically there.
While I'm sure there are circumstances this is needed, having the patient physically go to the hospital outpatient dept seems to defeat the purpose of keeping the patient safe at home and unexposed. I would think maybe for transfusions?? What specialty/situation is occurring?
 
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No, the patient is at home and the physician is physically in our outpatient hospital office for the telehealth call.
Since the physician is billing with POS 22 on the professional fund side and is receiving the facility based rate, why can't we bill Q3014 to cover the hospital expenses incurred by the physician at the hospital location, eg electric, rent, staff involved, etc?
The patient's originating site would be 'home', which would be documented by the physician, while the distant site would be the outpatient hospital location where the patient has been previously treated. From what we have been reading, the patient home can now be considered the originating site. We are holding any billing for Q3014 for our outpatient hospital clinics for oncology, radiation therapy, transplant, hepatology, immune deficiency, rheumatology and primary care locations until we receive clarification. Physicians are all on site treating other patients who need to physically come in.
 
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Q3014 does not compensate the hospital for expenses you mention - electric, rent staff - only for the costs or originating the telehealth service. Q3014 actually pays substantially less than the facility fees associated with providing an outpatient clinic visit, so if you bill this fee with the expectation of compensation for those other costs, you'll be taking a big reduction in your payments.

I think the guidance issued by CMS here is not completely clear, but I would be inclined to interpret this to mean that yes, you can bill Q3014 to compensate the hospital for the added expenses of using telehealth.

Normally, for an E&M service rendered by a physician in an outpatient hospital department, the hospital would bill G0463 and receive compensation for the facility expenses of the clinic visit under APC 05012. In the guidance you've cited above, it does say that they hospital may bill the Q3014, but what is not clear to me is if this is in addition to G0463 or in place of it. Q3014 is supposed to reimburse only the added expense of originating the telehealth service, not the other expenses incurred by the facility involved in the care of the patient, which are billed under the CPT/HCPCS codes appropriate to the services themselves. As mentioned above, since the patient is at home, the hospital is not actually originating the telehealth services or providing any actual services at the patient's home, so I would presume is being fully compensated for their services by billing G0463. It seems to me that if you only bill Q3014, then you will be underpaid, but if you bill both G0463 and Q3014, you will be overpaid. However, the wording of the guidance does say that the hospital may bill the originating fee in this situation and it seems to me that this would be in addition to billing for any other services provided.

I'm finding that some of the guidance surround COVID-19 and telehealth services that has been issued by CMS seems to have been made without a great deal of thought and/or depth of understanding of the billing and reimbursement implications and is creating more questions than answers. In your place, I would contact your local Medicare contractor to see if you can get additional guidance on this, though with the understanding that it likely will not be easy to get a final answer and you may be forced to use your best judgment and just make a decision as to how you interpret these guidelines.

I hope this helps some rather than making the situation even more confusing, but I totally understand why you're confused here - I think we all are these days.
 
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From the MAC for J8A under normal telehealth conditions:

"Submit the originating site fee using procedure code Q3014. ...
The above facilities cannot also submit charges for the distant site practitioner services under the facility National Provider Identifier (NPI). ... Submit the distant site services by the rendering provider on a CMS-1500 form or the electronic equivalent."

Our interpretation of this is that we may only bill the Q3014 not the normal facility fee and the Q3014. We bill the professional service on the 1500 with POS 19 or 22.

I agree that the CMS guidance in the exceptional circumstances is not clear. We have opted on the side of caution.
 
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Yes, this is definitely confusing, especially since there is sometimes vague guidance offered by CMS. Thank you for further explaining your situation. I hope I am not adding to the confusion, but I am trying to use my thought process so everyone can figure out the correct answer.
I do not bill for facilities and never have. That being said, I don't understand why the hospital would be able to bill G0463 if the patient is located at home. What services is the facility providing? What expenses would the facility would incur if the physician is performing telehealth while the patient is at home?
The guidance states Q3014 billable by hospital IF beneficiary's home is "considered to be a provider-based department of the hospital, and the beneficiary is registered as an outpatient of the hospital for purposes of receiving telehealth services billed by the physician or practitioner." What circumstances would be required for a patient's home to be considered part of the hospital?
I know, just more questions and confusion.... :unsure:
 
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Our facility has chosen to bill the Q3014 per the interim final rule guidance and we submitted a spreadsheet to our local MAC with all of our telehealth patient's addresses to be added as alternate outpatient facility locations. We are doing this to get some sort of reimbursement for these services as we are not getting reimbursed for the facility fee when billed on a UB for telehealth services.
 
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