Continuing Confusion Clouds CS Compliance

During this week’s Monitor Mondays broadcast, Ronald Hirsch, MD, vice president at R1 RCM, reminded listeners how confusing all the waivers and flexibilities associated with the COVID-19 pandemic have been, while noting that what is more amazing is that the confusion hasn’t stopped.

The latest confusion, Hirsch said, relates to the use of the CS modifier for visits during which a COVID test is ordered or administered, to indicate that the service is 100-percent covered. After three months of confusion, the Centers for Medicare & Medicaid Services (CMS) finally released a list of HCPCS codes that are eligible to have the CS applied in an update to MLN Matters, SE20011. And as Hirsch has reported here in the past, the only codes that are eligible are visit codes. The CS modifier cannot be applied on the line for the CT scan or EKG or any other testing done at the time of the visit.

He went on to clarify that this applies to Medicare only. For group and individual plans, the law specifies 100-percent coverage for the visit, and all items and services furnished during the visit.

“It’s different, and that’s obviously confusing. Not only is that confusing, but CMS seems to have left Q3014, the originating site fee, off of the eligible code list for outpatient hospitals – but they did include G0463, the facility fee, on the list,” Hirsch said. “Furthermore, the list of eligible codes for use by physicians includes the Q3014. It remains unclear why Q3014 is not on the outpatient hospital list, and it is likewise unclear when a physician would charge the originating site fee.”

To make things more uncertain, Hirsch reported that the CMS transmittal gives no instruction to the Medicare Administrative Contractors (MACs) about what to do with claims for which the CS was improperly applied and the provider was already paid at 100 percent.

“Will they automatically recoup the 20 percent and call it a done deal?” Hirsch asked. “But then how do supplemental plans know they are now obligated to pay the balance? What if the patient had not yet paid their deductible when they had that visit, and CMS covered it at 100 percent, but now the patient met their deductible with other services?”

Hirsch continued by asking if CMS will just recoup the whole amount, and make the provider resubmit a corrected claim. And finally, he asked, what are patients going to say when they get that surprise bill, months after their visit, where they were told that everything was 100-percent covered?

While the publication of this list is welcome, Hirsch said, the remaining lingering questions will continue to lead providers down a rocky road in ensuring smooth claim submission and processing.

Facebook
Twitter
LinkedIn
Email
Print

Chuck Buck

Chuck Buck is the publisher of RACmonitor and is the program host and executive producer of Monitor Monday.

Related Stories

Help: What Do I Do Now?

Help: What Do I Do Now?

The PHE has ended and the three-day SNF rule has returned. Following up on my previous article posted in April regarding the return of the

Read More

Leave a Reply

Please log in to your account to comment on this article.

Featured Webcasts

Mastering Good Faith Estimates Under the No Surprises Act: Compliance and Best Practices

Mastering Good Faith Estimates Under the No Surprises Act: Compliance and Best Practices

The No Surprises Act (NSA) presents a challenge for hospitals and providers who must provide Good Faith Estimates (GFEs) for all schedulable services for self-pay and uninsured patients. Compliance is necessary, but few hospitals have been able to fully comply with the requirements despite being a year into the NSA. This webcast provides an overview of the NSA/GFE policy, its impact, and a step-by-step process to adhere to the requirements and avoid non-compliance penalties.

Mastering E&M Guidelines: Empowering Providers for Accurate Service Documentation and Scenario Understanding in 2023

Mastering E&M Guidelines: Empowering Providers for Accurate Service Documentation and Scenario Understanding in 2023

This expert-guided webcast will showcase tips for providers to ensure appropriate capture of the work performed for a visit. Comprehensive examples will be given that demonstrate documentation gaps and how to educate providers on the documentation necessary to appropriately assign a level of service. You will gain clarification on answers regarding emergency department and urgent care coding circumstances as well as a review of how/when it is appropriate to code for E&M in radiology and more.

June 21, 2023
Breaking Down the Proposed IPPS Rule for FY 2024: Top Impacts You Need to Know

Breaking Down the Proposed IPPS Rule for FY 2024: Top Impacts You Need to Know

Set yourself up for financial and compliance success with expert guidance that breaks down the impactful changes including MS-DRG methodology, surgical hierarchy updates, and many new technology add-on payments (NTAPs). Identify areas of potential challenge ahead of time and master solutions for all 2024 Proposed IPPS changes.

May 24, 2023

Trending News