Yesterday, CMS issued an update
regarding the use of modifier CS for cost sharing waivers effective March 18,
2020 through the end of the Public Health Emergency (PHE).
Modifier CS should be appended to any evaluation and management (E/M) service
that was performed and resulted in the provider ordering one of the COVID-19
lab tests (U0001, U0002, 87635).
Modifier CS will identify the service as being subject to the cost sharing
waiver and will allow providers to receive 100% of the fee schedule payment,
including patient coinsurance and/or deductible amounts.
Modifier CS should be appended to the following E/M services, not the lab test
since cost sharing is already waived for labs.
- Office and other outpatient services
- Hospital observation services
- Emergency department services
- Nursing facility services
- Domiciliary, rest home, or custodial services
- Home services
- Online digital E/M services
The CMS instructions indicate providers should NOT charge Medicare patients
any co-insurance and/or deductible amounts for services reported with the CS
modifier.
If professional claims were not initially submitted with the CS modifier on or
after March 18, 2020, CMS MACs must be notified and a request made to resubmit
applicable claims with the CS modifier to get 100% payment.
For institutional claims not initially submitted on or after March 18, 2020,
providers and hospitals must resubmit the applicable claims with the CS
modifier to get 100% payment.
CMS also released a video on Medicare coverage and payment of virtual services
with answers to commonly asked questions about the telehealth benefit.
The entire update, including a link to the video, can be viewed here: https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-04-07-mlnc-se#_Toc37139913
We recommend referring to the CMS and other regulatory sites frequently as
changes and updates are occurring rapidly. CMS has a dedicated page on their
website for all emergency updates here: https://www.cms.gov/About-CMS/Agency-Information/Emergency/EPRO/Current-Emergencies/Current-Emergencies-page
HBE is available to assist with the training of your providers and staff on the
wide range of changes and can also provide assistance with policy
revisions, auditing and other compliance needs you may have. We will
continue to monitor these important developments.