Billing Telehealth Updates for the South Central Region – June 2022

Check out the most recent updates to the Arkansas, Tennessee, and Mississippi Virtual Visit Billing guides! As the COVID-19 Federal Public Health Emergency (PHE) remains in place, payors continue to comply with federal and state mandated flexibilities.  However, we are seeing most payors shift from temporary policies, that had numerous telehealth flexibilities, to permanent policies, that are slightly more restrictive.  Payors also continue to implement the 2022 released modifiers 93, FQ, and FR and place of service code 10.   Furthermore, almost all payors have eliminated elective cost share waivers, and only continue to offer the federally mandated cost share waiver for COVID-19 testing-related services.

Aetna

• Implemented use of FR, 93 and FQ modifiers.

BCBS of Arkansas

• Removed their temporary COVID-19 telehealth guidance and referred providers to utilize an updated version of their permanent policy.  The policy shift resulted in several significant updates, including an established patient relationship and a video component requirement for telehealth codes.

Cigna

• Cigna stated effective 07/01/2022, Place of Service (POS) 02 should be billed for virtual care services and not to bill POS 10 or the new virtual modifiers (93, FQ, and FR) until further notice.  Previously, they had instructed providers to begin utilizing modifiers 93 and FQ.  However, during the PHE, providers must continue to bill the POS that would have been used if the visit took place in person, and again, do not use the newly released modifiers.  This ensures proper reimbursement during the COVID PHE.

Medica

• Implemented use of modifier 93 and FQ

Medicare

• Added CPT 90901, 97537, 97763, 98960, 98961, 98962 to Temporary Addition for the PHE for the COVID-19 Pandemic
• Clarified use of the FQ modifier, as most MACs are instructing providers to not utilize until after the PHE ends.

State of Tennessee Law

• On April 8^th, 2022, the State of Tennessee Public Chapter No 807, house bill no 1843, was enacted into law Tennessee which authorizes that all healthcare services, along with behavioral health services, can be provided by HIPAA compliant audio only conversation when real-time interactive video is not available.  Providers should confirm and maintain documentation that the patient:
  • Does not own the video technology necessary to complete an audio-video provider-based telemedicine encounter
  • Is at a location where an audio-video encounter cannot take place due to lack of service
  • Has a physical disability that inhibits the use of video technology

  Providers should also notify the patient that the financial responsibility for the audio-only encounter will be consistent with the financial responsibility for other in-person or video encounters, prior to the audio-only telemedicine encounter

Tennessee Medicaid

• TennCare announced in June 21^st, 2022 that the MCOs will comply with the following:
  • Continue to allow payment for services originating at a site other than an office on a permanent
  • Continue to reimburse telehealth services at parity.
  • Comply with public Chapter 4 of the 111th General Assembly 2nd Extraordinary Session authorizes the terms and conditions for the electronic delivery of health care.
  • Comply with public Chapter 191 of the 112th General Assembly authorizes payment for behavioral health services provided via audio only telehealth when broadband is not accessible.
  • Comply with public Chapter 807 of the 112th General Assembly authorizes that all healthcare services along with behavioral health services can be provided by HIPAA compliant audio only conversation when real-time interactive video is not available.

United Healthcare

• Clarified telephone code usage