Updated COVID-19 fee-for-service billing FAQ addresses modifiers, RPM

CMS updated its novel coronavirus (COVID-19) fee-for-service billing FAQs on April 23 and May 1. The updated FAQs address the appropriate use of disaster-related modifiers, remote physiological monitoring (RPM), and more.

RPM can be provided to both new and established patients effective March 1 and for the duration of the public health emergency (PHE), according to the FAQ. The initiating visit requirement may be satisfied with a telehealth visit, and clinical staff may provide RPM services under general supervision. The direct supervision requirement may also be satisfied via audio/video real-time communications technology.

The FAQ also clarifies that although CPT ®code descriptors do not specify that an RPM device must be FDA approved, the device must meet the FDA definition of being a medical device.

Condition code DR (disaster related) and modifier -CR (catastrophe related) should be used for all institutional and non-institutional billing related to a formal COVID-19 waiver. Condition code DR should be used only on institutional claims, and modifier CR should be used on Part B claims by institutional and non-institutional providers. Claims for services or items that are not related to a COVID-19 waiver will not be denied if condition code DR or modifier CR are used.

Other new and updated FAQs address national and local coverage determinations, the use of telehealth in home health and hospice, and ambulatory surgical center billing.