IMPORTANT UPDATE FOR ALL MEDICARE PROVIDERS About the Incorrect Payment of 2024 Telehealth Claims (and other claim rejections)

By Barbara Griswold (last updated April 4, 2024, updates in red)

In a previous newsletter, I reported that all 2024 Medicare telehealth claims billed with Place of Service Code (POS) 10 were being underpaid.  These claims were being paid at a reduced “facility” rate instead of the proper “non-facility” rate for office visits.  (if you missed that article, click here).

While there was no doubt that the national Medicare organization had directed that as of 1/1/24 telehealth claims should be billed using the 10 POS code, clearly the regional Medicare Administrative Contractors (MACs) who process our claims hadn’t gotten the message.  When therapists called their MACs about this, they were often told (incorrectly) that they shouldn’t have used that POS code, or that the claims were paid correctly.

So, what’s the latest information on this issue?  

As recently as 2/23/24, one Medicare national representative in an email response stated “we are aware of an issue with reimbursement and are working towards a resolution.”  However, it is now evident that the directive has come down from Medicare to the MACs (or at least to some of them), acknowledging that POS 10 should be paying at the higher, non-facility rate.  But individual MACs seem to be addressing this at different speeds.

Here are some websites you can watch for updates.  REMEMBER AS A THERAPIST YOU ARE A PART B PROVIDER:

• CGS (Kentucky, Ohio): I could find no mention of this issue on their website as of 3/21/24 — even in their claim issues log.
• FIRST COAST (Florida, Puerto Rico) confirmed the issue, but as of 2/22/24 could not give a resolution date: read more here .  They also confirmed an issue with psychologists’ claims being denied in error — read more here
• NGS – for both Jurisdictions 6 (Illinois, Minnesota, Wisconsin) and Jurisdiction K (Connecticut, New York, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont), NGS said as of 2/22/24 that the issue had been corrected, and that “NGS will initiate a mass adjustment of all impacted claims with dates of service 1/1/2024 and after,” and that “no provider action was needed.” However, an update was posted on this page on 3/6/2024: “CMS advised NGS of a delay in the system correction for hits issue and the associated mass adjustment. Please continue to monitor this site for additional updates.” — Click here for more information.
• NORIDIAN Jurisdiction E (California, Hawaii, and Nevada) and Jurisdiction F states (Alaska, Arizona, Idaho, Montana, North Dakota, Oregon, South Dakota, Utah, Washington, Wyoming): As of 2/28/24 the website stated that “the system logic was updated on 02/27/24 to reflect a non-facility payment rate for claims received with POS 10. Noridian will initiate adjustments of claims with dates of service 01/01/24 through 2/26/24.” One provider was told not to rebill, as the claim may be denied as a duplicate.

 UPDATE 3/20/24: This was posted on the Noridian Website as of 3/20/24: “An additional update to the system logic was required and completed on 03/11/24. Noridian started initiating adjustments of claims with dates of service 01/01/24 through 03/10/24 on 03/15/24. Another update will be provided once all adjustments are initiated.” 

UPDATE 3/24/24: One provider who submitted Jan 2024 POS 10 claims received the reduced payment in February  for those claims, but reports this week he has received the adjustment from Noridian for the underpayment for those January claims. 

UPDATE 3/28/24: One provider contacted Noridian, who confirmed the claims would be reprocessed as if they are new claims, and thus SHOULD be resubmitted to secondary insurance, if applicable.  She was told the new claim will have a new claim number, and on the bottom of the EOB there will be the letters FB and a dollar amount after these letters, reflecting what you were paid originally. The amount of the new check should be the difference between what you should have been paid and what you did get paid. You may get one large check or several smaller batches of checks.  To sort things out, she was told to call: 1-855-609-9960. “Say ‘general’. You will be asked for your  NPI, PTAN, and the last 5 digits of your tax ID. Then just say “representative” and you will be connected with a live person.”

For Jurisdiction E states, read more here.  For Jurisdiction F states, read more here

• NOVITAS JL states (DC, DE, MD, NJ & PA) and JH states (AR, CO, LA, MS, NM, OK, TX) also confirmed the issue.  As of 3/21/24, the website still said “This issue is currently being investigated. Once research has been completed all impacted claims will be adjusted to the non-facility rate. There is no customer action needed.”  3/27/24 update: Medicare expert Susan Frager of PsychBillingCoach.com reports that she has now received claim adjustments for 2024, and that Novitas is now processing POS 10 2024 claims correctly.   Read more here for JL states, or read more here for JH states.  On this same page they indicated they were aware of a separate issue with MFT and counselor claims being rejected as ineligible providers.
• PALMETTO – Jurisdiction J (AL, GA, TN ) and Jurisdiction M (NC, SC, VA, WV): As of 3/27/24, I couldn’t find anything on their website about the POS issue, even in their claim issues log.

UPDATE 3/27/24:  Medicare expert Susan Frager of PsychBillingCoach.com reports that she got this response from Palmetto via chat on 3/26/24: “I do see Medicare is aware that this is an issue and is currently being processed, with an update to the system to resolve this matter. Medicare will initiate an adjustment for the claims affected by this. There are no further details regard a time frame for resolution, at this time. Please allow more time for the matter to be resolved.”  However, on 3/27/24, she and one provider reported they received an adjustment on a January POS 10 claim from Palmetto.
Palmetto  also indicated a separate issue with MFT and counselor claims being rejected as ineligible provider which they say has now been fixed — read more here)

• WPS – – J5 states (IA, KS, MO, NE) and J8 states (IN, MI): It took them until 2/15/24 to acknowledge the issue on their website.   They report “Place of Service (POS) 10 telehealth claims are pricing at the facility rate regardless of the provider specialty. CMS is currently researching this issue….Incorrectly priced claims will be adjusted” and say that no provider action is needed.

4/4/24 UPDATE– A Kansas reader reported that for sessions starting 3/7/2024, they were being paid at the correct amount for POS 10 from WPS, that they are now receiving the non-facility rate.  And as of 4/4/24, she received a large adjustment check for sessions from January through March from WPS. 

PLEASE LET ME KNOW IF YOU HAVE UPDATES TO THIS INFORMATION — click here.

Despite this mess, the experts I have spoken to still advise that you use the appropriate POS code for telehealth (10) for any 2024 Medicare claim you submit.  You can either submit claims with the reasonable expectation that — even if underpaid, they will be adjusted later, or you can hold off submitting claims until this mess gets clear up (but who knows when that will be?).   The good news is that either way, you should eventually be paid at the correct rate, and hopefully, they will be automatically adjusted without further effort on your part.

Got Medicare questions? I’m not a Medicare expert (except for documentation and audits).  For assistance with your Medicare questions, contact my Medicare expert colleague, Susan Frager, at www.PsychBillingCoach.com.