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Rural Health Clinics and Federally Qualified Health Centers Can Bill for Certain Virtual Communication Services

on Tuesday, 5 February 2019 in Health Law Advisory: Zachary J. Buxton, Editor

As of January 1, 2019, Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) may seek reimbursement for certain communication technology-based services, including short medical discussions and remote evaluations of recorded audio and/or video. In the preamble to the 2019 Physician Fee Schedule Final Rule, CMS recognized that allowing RHCs and FQHCs to bill for certain communication technology-based services and remote evaluation services will help patients, especially in rural areas where transportation is limited and distances are great, determine whether a visit to their local RHC or FQHC is necessary.

RHCs and FQHCs may bill for communication technology-based services and remote evaluation services (collectively “Virtual Communication Services” or “VCS”) using HCPCS code G0071 if the following conditions are met:

(1) Patient initiates the VCS;

(2) Patient receiving services had a billable visit with the RHC or FQHC within the previous year;

(3) An RHC or FQHC practitioner provides at least five (5) minutes of VCS; and

(4) VCS are not related to a service provided by the RHC or FQHC within the previous seven (7) days, and does not lead to a billable visit at the RHC or FQHC within the next twenty-four (24) hours or at the soonest available appointment.

CMS provided the following important clarifications in its response to comments:

• RHC and FQHC face-to-face requirements are waived for VCS provided to RHC or FQHC patients.

• RHCs and FQHCs may only bill for VCS when patient discussions require the skill level of the RHC or FQHC practitioner.

• Communication technology-based services and telehealth services are separate and distinct. Telehealth services are a substitute for an in-person visit; whereas, communication technology-based services are not.

• CMS agreed not to implement frequency limitations on VCS at this time.

• Patients utilizing VCS are still responsible for any applicable coinsurance requirement. CMS clarified that in providing these new services, RHCs and FQHCs should “inform their patients that coinsurance applies, and provide information on the availability of assistance to qualified patients in meeting their cost sharing obligations, or any other programs to provide financial assistance” when applicable.

• RHCs and FQHCs may bill for VCS even if the patient subsequently presents in an emergency room, urgent care center, or is treated by a non-RHC or FQHC practitioner, or receives a subsequent non-billable service from the RHC or FQHC (e.g., patient receives an injection) within the prohibited twenty-four (24) hour window.

• CMS clarified that, unlike telehealth services, VCS may be provided via audio-only technology (e.g., telephone).

Sean T. Nakamoto

1700 Farnam Street | Suite 1500 | Omaha, NE 68102 | 402.344.0500