Hospitals get some clarity from CMS on billing telemedicine services, but more required

July 14th, 2020

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Note:  The following article synopsis was NOT provided by HCPro. It was created by Find-A-Code/innoviHealth.

Article Overview

This premium article reviews recent CMS FAQ updates affecting hospital billing for virtual services during the public health emergency. It is aimed at hospital coders, revenue cycle staff, compliance teams, and outpatient billing professionals who need to understand how federal guidance applies to alternative care sites, provider-based department status, and related reporting considerations. The discussion focuses on general billing and operational implications for hospital services delivered outside the traditional facility setting, including distinctions that affect payment and enrollment review.

Why This Topic Matters

Hospitals need current guidance to bill virtual services correctly during the public health emergency and to understand how CMS treats different facility types and locations. The article helps readers evaluate whether their current workflows and location inventory align with federal billing expectations.

Article Sections

  1. Telemedicine during the PHE

    Introduces CMS guidance on services delivered through telecommunications technology during the public health emergency. The section discusses alternative care sites, hospital outpatient settings, and the broader policy context for virtual service delivery.

  2. Know your enrollment details

    Explains the importance of reviewing hospital enrollment and location records before expanding virtual service delivery. The section focuses on how hospitals should assess their enrolled sites and service arrangements in relation to current CMS guidance.

What You Will Learn

  • How CMS guidance addresses hospital services delivered via telecommunications technology during the public health emergency
  • Why outpatient location status matters when hospitals evaluate alternative care sites
  • What hospitals should review in their enrollment and location records before expanding virtual service delivery
  • How CMS guidance affects general reporting and payment considerations for hospital-based virtual services

Who Should Read This

  • Hospital coders
  • Outpatient billing staff
  • Revenue cycle teams
  • Compliance professionals
  • Hospital administrators
  • Provider-based department managers

Modifiers Discussed

  • HCPCS Level II: -PN
  • HCPCS Level II: -PO

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