Identify newly reimbursable outpatient services during the COVID-19 pandemic

June 16th, 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 article reviews CMS interim final rule guidance affecting hospital outpatient departments during the COVID-19 emergency. It focuses on the temporary ways outpatient services may be furnished and billed at alternate locations, the related relocation framework for provider-based departments, and the compliance and documentation considerations hospitals should track. The discussion is relevant to hospital coders, revenue cycle teams, compliance staff, and outpatient department leaders who need to understand emergency-era Medicare billing changes.

Why This Topic Matters

Hospitals needed updated rules for delivering outpatient care when patients could not come to standard department locations. The article helps readers understand which broad service categories, locations, and billing pathways were addressed by CMS and why these changes affect outpatient reimbursement and compliance.

Article Sections

  1. Outpatient therapy, education, and training

    This section discusses Medicare guidance for furnishing certain outpatient services through telecommunications technology during the public health emergency. It also addresses the general conditions tied to those services and the types of hospital outpatient department settings involved.

  2. In-person outpatient services

    This section covers services that are delivered in person at alternate hospital outpatient locations, including relocated provider-based departments. It also discusses how these services intersect with home-based care arrangements and supervision requirements.

  3. Originating site fees for telehealth

    This section explains the hospital outpatient department framework for billing originating site fees when telehealth is furnished to a patient in a relocated department location. It describes the general relationship between the patient location, the hospital, and the distant-site clinician.

  4. Relocation

    This section outlines the temporary relocation framework for provider-based departments and the related notification process to CMS. It also addresses the broader compliance context for hospitals using alternate outpatient locations during the emergency period.

What You Will Learn

  • How CMS addressed outpatient department billing during the COVID-19 public health emergency
  • The broad categories of outpatient services discussed in the interim final rule
  • How relocated provider-based departments factor into Medicare outpatient billing
  • What kinds of CMS notification and documentation topics are covered in the article
  • Why hospitals needed to monitor temporary compliance requirements during the emergency

Who Should Read This

  • Hospital coders
  • Outpatient revenue cycle staff
  • Compliance officers
  • Hospital finance teams
  • Provider-based department administrators
  • Health information management professionals

Modifiers Discussed

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

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