Question Medicare: Telephone Visit Guidelines & Referrals

kbrandt101

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I believe I have a comfortable grasp on what can be coded during the COVID-19 changes for my FQHCs but I'm running into a semantics issue and would love some input.

Normally there would be a medical service for multiple conditions and some of those may be referred to other specialists. A common example is a Behavioral Health referral.

The telephone guidelines state “nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment.”

So does this mean that if the phone visit with medical results in a visit/appointment with BH visit the code is not reported; rather the encounter is considered part of the preservice work of the subsequent E/M service, procedure, and visit? Regardless of if stated as a "referral"?

Personally, I'm leaning towards a referral is included per phone guidelines but there's just enough room for confusion so please let me know what you think.
 

kbrandt101

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Medicare Responses:

Question 1: So does this mean that if the phone visit with medical results in a visit/appointment with BH visit the code is not reported; rather the encounter is considered part of the preservice work of the subsequent E/M service, procedure, and visit? Regardless of if stated as a "referral"?

Answer: If the discussion between the patient and the RHC or FQHC practitioner is related to a billable visit furnished by the RHC or FQHC within the previous 7 days or within the next 24 hours or at the soonest available appointment, the cost of the RHC or FQHC practitioner’s time would be included in the FQHC PPS payment and is not separately billable.​

Question 2: If both are telephone only then it's just two G2025 codes and claims wise, it would be two G2025 services either the same day or within the same time period negating one due to telephone guidelines. So do we follow the telephone guidelines or the FQHC BH and Medical Rules?

Answer: FQHCs may furnish a medical telehealth visit and a behavioral health telehealth visit on the same day. If you are reporting a medical telehealth visit and a behavioral health telehealth visit on the same day, then you differentiate between the two by using the appropriate revenue codes. For medical telehealth visits you would use 052X and for behavioral health telehealth visits you would use 0900​
Hope this helps others as well. :)
 

ntreber

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As an FQHC you can bill for a medical visit and a BH visit on the same DOS. So I would say if the BH provider is employed by your FQHC that visit would not be considered part of the Medical telephone E/M service.
For example MD has phone E/M visit with patient due to increasing anxiety. MD refers patient to LCSW working in the same FQHC. LSCW has an opening the following day and sees patient.
Both services / visits should be billable.
 

kbrandt101

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As an FQHC you can bill for a medical visit and a BH visit on the same DOS. So I would say if the BH provider is employed by your FQHC that visit would not be considered part of the Medical telephone E/M service.
For example MD has phone E/M visit with patient due to increasing anxiety. MD refers patient to LCSW working in the same FQHC. LSCW has an opening the following day and sees patient.
Both services / visits should be billable.
That's why I started to question it but then we run into the billing aspect. If both are phone visits then they are billed using G2025, not the G046_ variation that would normally differentiate the BH and Medical services.

Normally it would be something like:
G0470 with 90832 for the behavioral health encounter​
G0467 with 99213 for the medical encounter​
Claim goes to medicare with the two g-codes to indicate two separate services.​

Due to telehealth and COVID-19 changes:
G0470 with 90832 and G2025 for the audio and visual telehealth behavioral health encounter​
G2025 for the audio-only medical encounter​
SDS claim would go to medicare with duplicate G2025 making the second G2025 not separately billable.​
If both are telephone only then it's just two G2025 codes and claims wise, it would be two G2025 services either the same day or within the same time period negating one due to telephone guidelines.​
If it weren't for the phone service guidelines and the use of G2025 I would be 100% in agreement. This is also why I'm stuck in this circular thought process without a solid answer. Do you still think the normal FQHC BH rules apply even with this coding issue?
 
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