Miscellaneous COVID-19 FAQs

No. Pharmacists are not eligible to bill Medicare directly for their professional services on a CMS-1500 form. However, pharmacists may provide services under the “incident to” provisions, in which case the physician or NPP would be able to bill for the professional services provided by the pharmacist or on the CMS-1500 form. (05/05/2020)

For hospital-based pharmacists, CMS is deferring to the state scope-of-practice regulations. If a pharmacist is functioning within state scope-of-practice regulations, does not contradict your state emergency or pandemic plans, is providing services incident to a physician/non-physician practitioner (NPP) order, and the service is not one that is covered under Medicare Part D, then the facility may submit services provided by a pharmacist on a UB-04 claim form. These must also meet other requirements, such as medical necessity and documentation.² Telephone services, such as CPT® codes 98966-98968 or HCPCS codes G2061-G2063, may be reported by auxiliary staff, which includes pharmacists.²

If a pharmacist employed by the hospital provides services to patients in temporarily relocated off-campus provider-based departments (which may include patients’ homes) using telecommunications technology in accordance with the extraordinary circumstances exception outlined in the interim final rule, CMS-5531-IFC, then these services may be submitted on the UB-04 as well. (05/06/2020)

¹CMS-5531-IFC, “Medicare and Medicaid Programs, Basic health Program, and Exchanges; Additional Policy and Regulatory Revisions in Response to the COVID-19 Public health Emergency and Delay of Certain Reporting Requirements for the Skilled Nursing Facility Quality Reporting Program”, page 25 (April 30, 2020)

²Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency, Telehealth Evaluation and Management (E/M) Services, page 2 (March 18, 2020)

Pharmacists and genetic counselors are not eligible to bill Medicare directly for their professional services on a CMS-1500 form. However, pharmacists and genetic counselors may provide services under the “incident to” provisions, in which case the physician or NPP would be able to bill for the professional services provided by the pharmacist or genetic counselor on the CMS-1500 form.

When pharmacists or genetic counselors are functioning as auxiliary staff of a hospital, CMS is deferring to the state scope-of-practice regulations. If the pharmacist or genetic counselor is functioning within state scope-of-practice regulations, does not contradict your state emergency or pandemic plans, is providing services incident to a physician/non-physician practitioner (NPP) order, and the service is not is covered under Medicare Part D, then the facility may bill for services that are provided by auxiliary staff on the UB-04 billing form. These must also meet other requirements, such as medical necessity and documentation.¹ (05/06/2020)

¹CMS-5531-IFC, “Medicare and Medicaid Programs, Basic health Program, and Exchanges; Additional Policy and Regulatory Revisions in Response to the COVID-19 Public health Emergency and Delay of Certain Reporting Requirements for the Skilled Nursing Facility Quality Reporting Program”, page 25 (April 30, 2020)

Effective January 1, 2020, CMS has suspended over 291,000 Procedure-to-Procedure (PTP) edits due to the COVID-19 public health emergency. This includes all of the PTP edits for the physicians that previously did not allow for reporting of CPT® code 99211, Office or other outpatient visit for the evaluation and management of an established patient that may not require the presence of a physician or other qualified health care professional. Usually, the presenting problem(s) are minimal. Typically, 5 minutes are spent performing or supervising these services, with other E/M codes when reported by the same provider for the same patient. The complete listing of suspended edits can be downloaded from the CMS website here. (05/06/2020)

COVID-19 convalescent plasma has not yet been approved for use by the U.S. Food & Drug Administration (FDA). Due to this, your facility will need to be enrolled in a clinical trial and follow the clinical trial claims submission process.¹ According to uscovidplasma.org, the plasma may be transfused either centrally or peripherally.² Code selection is based upon whether the patient is inpatient or outpatient, and whether the transfusion is central or peripheral. For outpatient accounts, CPT® code 36430, Transfusion, blood or blood components, would be appropriate. Inpatient accounts would use ICD-10-PCS codes within the 302xxxx range. (04/23/2020)

¹Recommendations for Investigational COVID-19 Convalescent Plasma

²Clinical Investigator’s Brochure for Use of Convalescent Plasma to Treat Coronavirus-19 (COVID-19) Disease

The new time guidelines apply to Medicare and Medicaid. Adoption by other payers will be a payer-specific decision.¹ We recommend that you check with other payers to determine if they are adopting the new time guidelines during the public health emergency. (04/23/2020)

¹Medicare and Medicaid Program; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency, pages 141-142

It is not possible to directly map codes for telephone visit services to new and established E/M codes. Codes should be selected based upon the documentation in the medical record and in accordance with the specific payer guidance. Additionally, it appears that at least certain state Medicaid programs are allowing the use of CPT®codes 99441-99443 to report telephone services. Therefore, we would recommend checking with your particular payers regarding appropriate reporting of these services to ensure accurate coding and reimbursement. (04/23/2020)

Teaching physicians can provide supervision virtually through audio/video real-time communications technology. Note that this does not apply in the case of surgical, high-risk, interventional, or other complex procedures, services performed through an endoscope, or anesthesia services. When the term “audio/video real-time communications technology” is used, this does not include audio-only communication.¹ (04/23/2020)

¹Teaching Hospitals, Teaching Physicians and Medical Residents: CMS Flexibilities to Fight COVID-19, page 1