On Tuesday, July 28, CMS updated the COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing to provide guidance on billing HCPCS code G0463 when a physician is providing a remote service to a patient in the patient’s home, which has been designated as a provider-based department.  As we noted last week (see our memorandum of July 22), CMS has taken inconsistent positions on this issue in its Office Hours calls—first stating that billing a G0463 is not permitted, then stating that it is, and then reversing course again to prohibit it.  In its first official written guidance on the subject, CMS changed course once again.

In the new FAQs, CMS creates a distinction between billing for a telehealth service with the originating site fee (Q3014) and billing for a remote service with the G0463 code, depending on where the physician (not the patient) is located.  CMS stated that if a physician is practicing from a hospital that has registered the patient as a hospital outpatient in the patient’s home, which is serving as a provider-based department of the hospital, the physician and patient would be considered as “in the hospital” and the G0463 code would be billed.   Alternatively, if the physician is not seeing the patient from the hospital (such as if the physician is working from home at the time of the visit), then the hospital would bill the originating site fee (Q3014) not the G0463 code.

Hospitals should use the decision tree from the FFS FAQs (page 126) to determine whether billing the Q3014 or G0463 code is appropriate for their particular situation.

For further questions regarding this or other COVID-19 matters, please contact Mark Fitzgerald at Mark.fitzgerald@powerslaw.com  or Natalie Dobek at Natalie.dobek@powerslaw.com or the Powers professional with whom you normally work.