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COVID-19 Update 04/24/20 – More on Medicare Telehealth Services-related Changes

As providers and practices continue to determine the best way to safely care for their patients while navigating the ever-changing regulatory requirements related to COVID-19, HCCI is committed to continuing to provide accurate, clarifying and timely information.

“Medicare telehealth services” refer to a certain list of services that would normally be provided in-person, but due to the Public Health Emergency, are temporarily being allowed by Medicare in all locations when they are furnished using two-way audio and video technology that permits real-time communication between the provider and the patient who are in different locations.

Medicare has also previously allowed these services in geographic areas that were rural or designated as a Healthcare Professional Shortage Area (HPSA), subject to distant and originating site requirements (temporarily waived).

As a result of the interim final rule published on 3/26/20, for visits conducted via telehealth, for Medicare’s purposes, providers should report the Place of Service (POS) where the patient would have been seen face-to-face (to allow for non-facility rate payment) and use modifier 95 to identify it as a telehealth service. Telehealth services no longer require POS 02.

The following are not considered Medicare telehealth services because they would not normally be provided face-to-face. Instead, providers should report the POS where the service was rendered, with no modifier required.

  • Telephone Evaluation & Management (E/M) Services: CPT code range 99441-99443 and CPT code range 98966-98968
  • Virtual Check-in (phone call): HCPCS code G2012
  • Review of recorded video and/or photo or image: HCPCS code G2010
  • E-visits (patient portal communications over a 7-day period): CPT code range 99421-99423 and HCPCS code range G2061-G2063
  • Remote Patient Monitoring: CPT codes 99453-99454, 99091, 99473-99474, 99457, 99458

Other Modifiers

  • CS Modifier: Physician and practitioner services that lead toeither an order for, or administration of, a COVID-19 lab test are not subject to a co-pay or deductible charges. The CS Modifier is added to the physician/practitioner service to define this circumstance and allow the claim to process without co-pay or deductible application.
  • CR Modifier: Catastrophe/disaster-related; required when an item or service is impacted by an emergency or disaster and Medicare payment for that item or service is conditioned on the presence of a “formal waiver.” Please note telehealth services are excluded from CR modifier use, so do not report for telehealth services. Be sure to follow the guidance provided by your local Medicare Administrator Contractors (MAC) as a recent NGS article advised to use CR for telephone E/M services.

Additional Key Updates

Previous HCCI Home-Based Primary Care-Specific Updates

Disclaimer: This information is current as of 4/24/2020. COVID-19 guidelines are changing daily. Please note for the purposes of the Home-Based Primary Care (HBPC) population: The Home Centered Care Institute (HCCI) focuses our content on CMS guidelines relevant for traditional Medicare billing. It’s always recommended to check with local MACs for specific guidance for your geographic region.

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Infection Control in Home-Based Primary Care

As home-based primary care (HBPC) expands across the U.S., we’re reminded of how critical this model of care is, particularly during a Public Health Emergency like COVID-19.  Because of this, and more than ever, HBPC providers must keep infection surveillance, prevention, and control efforts top-of-mind to protect patients, caregivers, household family members, and themselves. To this end, HCCI offers these important reminders for providers about basic infection control strategies:

  • When scheduling appointments, ask about the travel history and current state of health of the patient and all household contacts.
  • Use proper hygiene and follow recommendations for transporting, storing and disposing of supplies.
  • Disinfect the medical bag and supplies before and after every visit.
  • Assess the home environment before entering and use appropriate personal protection equipment (PPE).
  • Position the medical bag and laptop/tablet on clean, dry surfaces, out of reach of children and pets.

For more information about practical infection control strategies for HBPC providers, download HCCI’s Infection Control Resource Guide.  You can also access more information and resources on the HCCI COVID-19 Information Hub, including HCCI’s online course, Infection Control in Home-Based Primary Care, available at no cost now through June 30, 2020.


Help HCCI Combat COVID-19 and Participate in GivingTuesdayNOW

giving tuesday now

The COVID-19 pandemic has spotlighted the important role that home-based primary care (HBPC) providers are playing in caring for homebound patients who are generally the most vulnerable to the outbreak. HBPC also helps keep these patients out of hospitals and clinics, unless necessary, which fights the spread of the virus, provides an isolated place for COVID-19 testing, and eases the strain on already stretched hospital and clinic resources, including staff, beds and personal protective equipment.

The Home Centered Care Institute is playing a key role in supporting HBPC providers during this time by educating them on COVID-19 topics and areas, such as identifying HBPC-specific changes in CDC and Centers for Medicare & Medicaid Services (CMS) updates; discussing best practices for processes and protocols; and following appropriate infection control procedures. HCCI does this in a variety of ways, including providing free webinars, online courses and resources; creating an online LinkedIn community especially for HBPC providers to discuss the pandemic; launching a video interview series called “HCCI Conversations with…,” and continuing to spread awareness of the importance of HBPC in fighting the pandemic through recent media opportunities with CNN, Hospice News and Kaiser Health News , among others.

At the same time, HCCI is also an official participating organization in the upcoming “GivingTuesdayNow” campaign. GivingTuesdayNow is a global day of giving and unity that will take place on May 5, 2020, as an emergency response to the unprecedented need caused by COVID-19.

Learn more about how you can donate to help HCCI combat COVID-19 and, by doing so, be part of the GivingTuesdayNow campaign.

Please then also consider donating on a longer-term basis. Because, as the pandemic evolves and the world slowly emerges into a “new normal,” HBPC will continue to play a critical role for these patients and others – many of whom may be in your own family or community.

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The Power of Three: Grant Recipients Continue to Advance Home-Based Primary Care

In the Fall of 2019, The John A. Hartford Foundation awarded a three-year, $1.6M grant entitled, Moving and Scaling Home-Based Primary Care Phase II: Quality, Training and Advocacy. The project aims to improve care for the more than two million older adults who are the “invisible homebound” with functional impairments and frailty. This phase builds on the success of the initial grant phase, with the same organizations leading three complementary grants.

While each organization has its own unique deliverables, they continue to work in close collaboration to achieve the overall goal ─ increasing access to high quality, home-based primary care that leads to improved outcomes for both patients and caregivers. Following is an overall look at the grant recipients and their respective projects:

  • The American Academy of Home Care Medicine (AAHCM) is charged with developing a home-based primary care (HBPC) national practice directory. “Our mission in phase two is to create an online Home-Based Primary Care National Practice Directory site to connect patients to practices and refer other providers to home-based primary care providers,” said Brent Feorene, executive director for AAHCM. “The site will also serve as a provider resource for timely information about HBPC, new payment policies and educational content on quality of care. Ultimately, this project will help expand services to populations with serious advanced illness.” The directory is being built using a human-centered design process to ensure it encompasses all the information its various users need and is slated to launch during the fourth quarter of this year.
  • The National Home-Based Primary Care Learning Network led by Dr. Christine Ritchie at Massachusetts General Hospital and Dr. Bruce Leff at Johns Hopkins University School of Medicine will work to expand and enhance a national quality improvement Learning Network among HBPC practices. “The Learning Network will be comprised of practices that identify new and ongoing quality and practice issues in HBPC, develop practice-guided strategies to address these issues, and use real-time, practice-based, data-driven initiatives to evaluate the effectiveness of these efforts,” said Naomi Gallopyn, program manager for Massachusetts General Hospital. The group recently completed a similar project with nine HBPC practices and is now seeking applications to grow their Learning Network with an additional 10 practices (deadline is April 24, 2020). For more information, please visit
  • The Home Centered Care Institute (HCCI) will build on its strong foundation and leverage the expertise of its staff, faculty and partners to develop and implement an enhanced multi-modal educational strategy. “HCCI is uniquely qualified to meet the current and growing demand for education and training of the home-based primary care workforce,” said Melissa Singleton, Chief Learning Officer for HCCI. “By further enhancing our offerings around clinical and practice management topics, we are equipping providers around the country with the knowledge and skills to be successful. Ultimately, this grant will help achieve HCCI’s goal of expanding the workforce, enhancing patient and caregiver satisfaction, lowering overall costs, and providing higher quality care for home-limited patients.”

“Increasing access to high-quality, home-based primary care is one profoundly important way that we can make health care more age-friendly and focused on what matters to older adults and their families,” said Scott Bane, JD, MPA, Program Officer at The John A. Hartford Foundation.  “The collaborative work of these three organizations will help more providers deliver the right kind of care in the right place for older adults with the most complex needs.”

About The John A. Hartford Foundation

The John A. Hartford Foundation, based in New York City, is a private, nonpartisan philanthropy dedicated to improving the care of older adults. Established in 1929, the Foundation has three priority areas: creating age-friendly health systems, supporting family caregiving, and improving serious illness and end-of-life care. For more information, visit and follow @johnahartford.

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COVID-19 Update 04/08/20 – Additional Key Information and Flexibilities in the CMS Interim Final Rule

In addition to changes in the Centers for Medicare & Medicaid Services (CMS) Interim Final Rule discussed in our previous update, Providers and practices should be aware of the following additional information and waiver flexibilities in the rule:

  • Home Health Agencies can now provide additional services to patients via telehealth if it’s part of the patient’s plan of care and does not replace the needed in-person care as ordered in the plan of care.
  • Hospice Organizations can provide services to Medicare patients via telehealth if feasible and appropriate to do so.
  • Clinicians now have maximum flexibility in determining patient needs for respiratory-related devices and equipment and the flexibility for more patients to manage their treatments at home. The current National Coverage Determinations (NCDs) and Local Coverage Determinations (LCDs) that restrict coverage of these devices and services to patients with specific clinical characteristics do not apply during the Public Health Emergency. For example, Medicare will cover non-invasive ventilators, respiratory assist devices, and continuous positive airway pressure devices based on the clinician’s assessment of the patient. So, in summary, on an interim basis, CMS will not enforce clinical indications across respiratory (including home oxygen), home anticoagulation management, and infusion pump NCDs and LCDs (including articles).

The above policies include but are not limited to the following:

  • Home Oxygen
  • Continuous Positive Airway Pressure for Obstructive Sleep Apnea
  • Respiratory Assist Devices (ventilators for home use)
  • Intrapulmonary Percussive Ventilator
  • Oxygen and Oxygen Equipment (for home use)
  • Home Prothrombin Time/International Normalized Ratio (PT/INR) Monitoring for Anticoagulation Management
  • Infusion Pumps
  • External Infusion Pumps

For additional information:

Previous HCCI Updates related to COVID-19:

Disclaimer: This information is current as of 4/08/2020. COVID-19 guidelines are changing daily. Please note for the purposes of the Home-Based Primary Care (HBPC) population: The Home Centered Care Institute (HCCI) focuses our content on CMS guidelines relevant for traditional Medicare billing. It’s always recommended to check with local MACs for specific guidance for your geographic region.

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COVID-19 HCCI Update: Week of 03/30/20

During HCCI’s recent webinar, “The Impact of COVID-19 on Home-Based Providers, Practices, and Patients we encouraged practices to reach out to their local Medicare Administrator Contractors (MAC) for specific guidance on whether home-based primary care (HBPC) providers can bill for the home and domiciliary visit CPT code ranges under the 1135 telehealth waiver.

New Centers for Medicare & Medicaid Services (CMS) Fact Sheet

On March 30, CMS published an important new fact sheet announcing that they’re adding 80 additional services when furnished via telehealth. CMS also added home and domiciliary CPT codes to the list. These codes can now be billed for when performed via telehealth using two-way audio and video.

Following are the home and domiciliary visits added for payment during the COVID-19 Public Health Emergency:

  • New patient domiciliary visits CPT code 99327 (Level 4 New/60 minutes) and CPT 99328 (Level 5 New/75 minutes)
  • Established patient domiciliary visits CPT code range 99334-99337 (complete levels of service 1-4)
  • New patient home visits CPT code range 99341-99345 (complete levels of service 1-5)
  • Established patient home visits CPT code range 99347-99350 (complete levels of service 1-4)

Please note that CMS advised they expect providers to use the Evaluation & Management (E/M) code that best describes the nature of the care they are providing, regardless of the physical location or status of the patient (e.g., HBPC providers using home and domiciliary visits rather than the office visit code set).

As a result of the new interim final rule, CMS also did the following:


  • Finalized its interim policy of requiring modifier 95 for E/M services furnished via telehealth. CMS no longer requires the use of Place of Service 02 for telehealth; instead, providers are instructed to report the POS that would have been reported if the visit was conducted face-to-face (e.g., POS 12 for home) and modifier 95 which identifies the service as telehealth. Following is a complete description:
    • Modifier 95 is used to indicate services performed via real-time interactive audio and visual telecommunication system.
    • You can also refer to the CMS interim final rule for a complete list of covered telehealth services.
  • Added CPT code ranges for Telephone E/M services which allow for payment of audio-only interactions:
    • CPT 99441 Telephone E/M 5-10 minutes; National Facility Payment $13.32
    • CPT 99442 Telephone E/M 11-20 minutes; National Facility Payment $26.64
    • CPT 99443 Telephone E/M 21-30 minutes; National Facility Payment $39.60
  • Other qualified healthcare professionals who can bill for telehealth services per CMS include licensed clinical social workers, clinical psychologists, physical therapists, occupational therapists, and speech-language pathologists. These providers can bill for telephone E/M services using the following CPT codes:
    • CPT 98966 Telephone E/M 5-10 minutes Non-Physician Practitioner; National Facility Payment $13.32
    • CPT 98967 Telephone E/M 11-20 minutes Non-Physician Practitioner; National Facility Payment $26.64
    • CPT 98968 Telephone E/M 21-30 minutes Non-Physician Practitioner; National Facility Payment $39.60
  • Clarified that their interim policy for telephone E/M, virtual check-ins, and E-visits can now be furnished to new and established patients. POS 02 and modifier 95 should not be used in these instances since they are not considered to be “telehealth” services. Instead, the POS where the services would typically be rendered should be used.
  • Retained the requirement that the Communication Technology-Based Services (CTBS), e.g., virtual check-ins and telephone E/M, described above cannot be related to an E/M visit within the past 7 days and cannot result in the need for a face-to-face visit or a telehealth E/M visit. (To see additional information on CTBS, refer to the links for the previous HCCI COVID-19 articles below.)

Additional Legislation Updates

  • On March 25, the United States Senate passed H.R. 748 – the Coronavirus Aid, Relief, and Economic Security Act (The CARES Act).
    • The Home Centered Care Institute (HCCI) is pleased to announce that section 3708 of the CARES Act allows Nurse Practitioners (NP), Physician Assistants (PA), and Certified Nurse Specialists (CNS) to prescribe and certify home health services and be reimbursed for such services under Medicare Parts A & B.
    • With the new act, Advanced Practice Providers can now establish the plan of care and fulfill plan review requirements. This also applies to Medicaid requirements and must be implemented within 6 months of the date of enactment of the act.
  • CMS also announced the Expansion of the Accelerated and Advance Payments Program, which may be beneficial for practices and providers struggling with cash flow issues due to COVID-19.
  • Home Health and Hospice agencies also have increased flexibility in the types of services they can perform via telehealth, which is further described in the interim final rule.

Please continue to visit HCCI’s COVID-19 Information Hub When you’re on the site, look for the word “New,” which will flag the information added that week.

You can also join the conversation happening in the new Home Centered Care Institute COVID-19 Group on LinkedIn. Once you’re logged into LinkedIn, join your colleagues who are already members by searching the name of the group on LinkedIn and requesting to join – or by going directly to to make the request.

Previous HCCI COVID-19 Update Articles:

Disclaimer: This information is current as of 4/1/2020. COVID-19 guidelines are changing daily. Please note for the purposes of the Home-Based Primary Care (HBPC) population: The Home Centered Care Institute (HCCI) focuses our content on CMS guidelines relevant for traditional Medicare billing. It’s always recommended to check with local MACs for specific guidance for your geographic region.