Take heed of new guidance CMS issued today to ensure you're getting paid in full for certain COVID-19 encounters. When taking the liberty to waive patient's cost-sharing, you should be appending your COVID-19 testing-related claims with the modifier CS.
Modifier CS, effective for services on or after March 13, should be applied when billing for an E/M service that results in or assesses the need for a COVID-19 lab test, CMS states in an email sent to providers April 7.
Providers should use the CS modifier on applicable claim lines to identify the service as subject to the cost-sharing wavier for COVID-19 testing-related services," the agency instructs. The modifier signals your Medicare administrative contractor (MAC) that it should reimburse the claim at 100% -- including the amount that would have been paid by the patient.
Under the Families First Coronavirus Response Act, cost sharing is waived for Medicare Part B claims when a provider "orders or administers COVID-19 lab test U0001, U0002 or 87635."
It appears that CMS hs formulated the CS billing criteria to ensure its MACs are paying 100% of the fee schedule rates on professional claims for such services during the emergency.
This isn't the first time the CS modifier has turned up during an emergency. In 2010,
CMS issued the CS modifier to identify services related to the treatment of illnesses or injuries caused by the 2010 oil spill in the Gulf of Mexico.
For the current crisis, questions remain on the extent of CS use. In one part of its April 7 transmittal, the agency specifies that CS-appended claims must be linked to one of the eligible lab codes. But in another part, CMS says the claims must be "related to furnishing or administering such a test or to the evaluation of an individual for purposes of determining the need for such a test." The latter part of the guidance appears to suggest that an evaluation alone would warrant use of the modifier.
The use of the CS modifier was approved for services on or after March 18, 2020, and through the conclusion of the public health emergency. Eligible E/M encounters include office and outpatient services, hospital observation services, ER codes, nursing facility services, home services and "online digital" E/M services, the agency says.
How should you handle claims that you've submitted since March 18 without the CS modifier?
"For professional claims, physicians and practitioners who did not initially submit claims with the CS modifier must notify their Medicare Administrative Contractor (MAC) and request to resubmit applicable claims with dates of service on or after 3/18/2020 with the CS modifier to get 100% payment," CMS states.
"For institutional claims, providers, including hospitals, CAHs, RHCs and FQHCs, who did not initially submit claims with the CS modifier must resubmit applicable claims submitted on or after 3/18/2020, with the CS modifier to visit lines to get 100% payment," the agency adds.