June 16, 2021: Attention Federally Qualified Health Centers (FQHC), Rural Health Clinics (RHC), and Tribal Health Center (THC)Providers: G2025 Telemedicine Distant Site

June 16, 2021 Attention Federally Qualified Health Centers (FQHC), Rural Health Clinics (RHC), and Tribal Health Center (THC)Providers: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law. Section 3704 of the CARES Act authorizes RHCs and FQHCs to furnish distant site telehealth services to Medicare beneficiaries during the COVID-19 public health emergency (PHE). The Center for Medicare and Medicaid Services (CMS) is requiring HCPCS G2025 on Medicare distant site telehealth services, effective January 27, 2020, until the end of the PHE. The HCPCS description of G2025 is "distant site telehealth services." This guidance from Medicaid will run concurrent with Medicare through the end of the PHE.

Prior to the COVID-19 PHE, Medicaid was already allowing billing and reimbursement for telehealth distant site services. For clinics to receive Prospective Payment System (PPS) or All-Inclusive Rate (AIR) reimbursement for Medicaid distant site telehealth services, the Clinic - Payment Codes (G-Codes and T-Code) and the accompanying Clinic Qualifying Visit code are required to be billed in combination (MSA 17-10). Although Medicare may not require the Clinic - Payment Codes and the accompanying Clinic Qualifying Visit code to be billed with G2025, current Medicaid billing and reimbursement policy does require the combination of coding to be on the claim to receive PPS/AIR Medicaid reimbursement consideration.

Claims and encounters sent to Medicaid for dual-eligible (Medicare/Medicaid) beneficiaries with G2025 listed as the stand-alone HCPCS on the claim will not generate the PPS/AIR from the Michigan Medicaid program. Dual eligible claims and encounters must be submitted to the Michigan Medicaid program according to current Medicaid clinic billing and reimbursement policy. Detailed HCPCS/CPT coding with the associated line-item charges listing the visit that qualifies the service for an encounter-based payment and all other services furnished during the encounter are required for Medicaid PPS/AIR reimbursement.