CMS Is Making It Easier for Rural Health Clinics and Federally Qualified Health Centers to Provide Services and Receive Payments
Payment Changes for Services Provided by RHCs and FQHCs During the PHE
The Coronavirus Aid, Relief and Economic Security Act (CARES Act), which was signed into law on March 27, 2020, permits RHCs and FQHCs to provide distant site telehealth from any location that is approved as a distant site under the Physician Fee Schedule (PFS) by any practitioner working for the RHC or the FQHC within their scope of practice.
CMS is required to set a rate for distant site telehealth providers, and has set a payment rate of $92 for telehealth distant site services provided by RHCs and FQHCs. Effective March 1, 2020, RHCs and FQHCs are not permitted to collect coinsurance for services related to COVID-19 testing, however the payment that will be made to the RHCs and FQHCs for COVID-19 testing services will include the coinsurance amount. All RHC and FQHC telehealth claims, and claims including co-insurance payments for COVID-19 services, will be reprocessed and paid in July 2020, provided the RHCs and FQHCs utilize the correct modifiers when submitting the claims.
CMS will also reimburse RHCs and FQHCs for the new online digital evaluation and management codes at a new, higher rate, effective for claims submitted after March 1, 2020, with the HCPCS Code G0071. MACs will reprocess any previous claims paid at the lower rate.
RHCs and FQHCs are also provider types eligible for advanced and accelerated payments if they meet the required qualifications. Providers generally must begin repayment of advanced and accelerated payments 90 days from the date the payment has been issued, however, the time to begin repayment has been extended to 120 days after the payment has been issued.
Expanded Home Health Services May Be Provided by RHCs and FQHCs
Prior to the waiver, RHCs and FQHCs could provide visiting nursing services by an RN or LPN to homebound patients under an individual plan or treatment only in areas where there was shortage of home health agencies (HHAs). Effective March 1, 2020, the waiver automatically designates the areas typically serviced by RHCs and areas included in the FQHC service plan as having a shortage of HHAs, permitting the RHCs and FQHCs to provide these types of services to homebound patients without having to seek a waiver.
RHCs and FQHCs Can Provide Virtual Communication Services
RHCs and FQHCs are now permitted to provide online digital evaluation and management services. These are non-face-to-face visits that are initiated by a patient and utilize a patient portal. There are codes that have been added for RHCs and FQHCs to utilize when providing these online digital evaluation and management services, which depend on the amount of time spent with the patient in a cumulative 7 day period.
RHCs and FQHCs Can Relax the Direct Supervision Requirements to Obtain Consents
While a beneficiary must still consent to receive all services, including care management and non-face-to-face services, during the PHE, CMS has relaxed the requirement that the consent for services be obtained by someone working under the direct supervision of the billing practitioner. The waiver permits RHCs and FQHCs to obtain the waivers utilizing personnel under the general supervision of the RHC or FQHC practitioner, including an employee, independent contractor, or leased employee.
RHCs and FQHCs Are Unique Providers but Need Support Just as Other Provider Types
CMS recognizes that RHCs and FQHCs require assistance and support like other types of providers. CMS has increased flexibility for RHCs and FQHCs to enable them to provide all necessary services to their patients during the PHE, and has indicated that additional changes will be made to as needed to ensure that RHC and FQHC patients have access to needed services during the pandemic.