Q&A: Billing for DSMT provided via telehealth

Monday, April 13, 2020

Q: Can a hospital bill for a nutritionist and a dietitian deliver diabetes self-management training (DSMT) via telehealth on a UB claim? Nutritionists and dietitians are on the list of distant site practitioners, although registered nurses are not.

A: Not yet. It is true that the Medicare Benefit Policy Manual, Chapter 5, discusses UB billing for DSMT services and that HCPCS codes G0108 or G0109 are on the list of approved telehealth services. Furthermore, for the duration of the public health emergency, these clinician types can bill virtual check-in visits with codes G2010 or G2012 and e-visits with codes G2061-G2063. This is discussed in CMS’ interim final rule put on display March 30. However, this was made even more clear in CMS’ responses to questions in the second townhall nationwide call held on March 31. During that call, CMS responded to questions concerning hospital-employed clinicians billing telehealth. CMS representatives said that the agency is working on it with the new authorities granted via the CARES Act, but that the CMS-1744-IFC speaks to professional Part B billing only.

Therefore, if hospital-employed clinicians have NPIs, then they can enroll in Medicare and re-assign their benefits to the employing hospital and the hospital can submit 1500 claims for these telehealth services. Also, if the patient does physically come to the hospital, then the hospital is able to bill the site origination fee Q3014.

CMS stated that it will be releasing more rules in the future concerning telehealth by hospital-employed clinicians concerning DSMT and other clinician types and services such as therapy. In the meantime, the hospital should register and track these services, bill 1500 claims if the clinician is enrolled and has reassigned benefits to the hospital, or hold and write off claims until CMS releases additional information.

Editor’s note: Valerie Rinkle, MPA, CHRI, regulatory specialist for HCPro in Middleton, Massachusetts answered this question. This answer was provided based on limited information and does not constitute legal advice.

More Like This

Get Your Coding Right the First Time—Prior to Billing—with Automated Analysis from eValuator

Get Your Coding Right the First Time—Prior to Billing—with Automated Analysis from eValuator

2021 NAHRI Leadership Council Research Series: Takeaways for Revenue Integrity Professionals