COVID-19 Update: CMS Paying Providers for Counseling Services

On July 30th, 2020, the Centers for Medicare and Medicaid Services (CMS) announced that it will begin paying qualified healthcare professionals (i.e., MD, NP, PA, CNS, CNM) for counseling services provided to traditional Medicare beneficiaries when related to the administration of a COVID-19 test. Clinicians are advised to use the appropriate Evaluation and Management (E/M) CPT code to bill for time-based counseling services that encourage and educate patients on the importance of quarantine and isolation regardless of showing symptoms and even before test results are received.

As part of the announcement, CMS released a  “Billing for COVID-19 Testing Counseling Checklist” that reviews what specifically needs to be discussed and documented when billing for counseling services related to COVID-19 testing.

According to CMS guidance, clinicians should discuss and document the following during these encounters:

• The general signs and symptoms of COVID-19.
• The immediate need to separate from others by isolation or quarantine, particularly while awaiting test results.
• The importance of informing close contacts of the person being tested (e.g., family members) so they can take necessary precautions while the patient is awaiting test results.
• If a test is positive, the patient will be contacted by the public health department to learn the names of the patient’s close contacts. During the counseling session, the patient should be encouraged to speak with the health department if they call.
• The services that may be available to assist the patient in successfully isolating or quarantining at home (e.g., meal delivery services).

Time-based billing CPT rules apply, meaning the provider will also need to include a statement within their documentation of the total amount of time spent, and that more than 50% of it was dominated by counseling related to COVID-19 testing precautions and education. The documentation must include specific details and be as descriptive as possible about the conversation between the provider and patient.

To review additional guidance published by CMS, review the Medicare Learning Network (MLN) fee-for-service publication (pages 7-8).

Disclaimer: This information is current as of 8/03/20. 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 its 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. Medicare Advantage and commercial payor policies will vary.