Clients and Friends,
NARHC News published the following newsletter earlier this week on the October 1 changes for RHC Billing on use of CG modifier.
This is from the CMS announcement on use of CG modifier:
In April 2016, CMS instructed RHCs to hold claims only for a billable visit shown in red on the RHC QVL until October 1, 2016. Upon billing these claims and/or for claim adjustments beginning on October 1, 2016, RHCs shall add modifier CG (policy criteria applied) to the line with all the charges subject to coinsurance and deductible. The subsequent paragraph explains modifier CG further.
Beginning on October 1, 2016, the MACs will accept modifier CG on RHC claims and claim adjustments. RHCs shall report modifier CG on one revenue code 052x and/or 0900 service line per day, which includes all charges subject to coinsurance and deductible for the visit. For RHCs, the coinsurance is 20 percent of the charges. Therefore, coinsurance and deductible will be based on the charges reported on the revenue code 052x and/or 0900 service line with modifier CG. RHCs will continue to be paid an all-inclusive rate (AIR) per visit.
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HCs shall report modifier CG on one revenue code 052x and/or 0900 service line per day, which includes all charges subject to coinsurance and deductible for the visit.
Unlike the HCPCS change, in this case, the Date of Service is NOT the operative date but rather the ABILITY of the MAC to accept and process claims using the CG modifier. Note the highlighted words above. On October 1, the MACs will be able to ACCEPT claims with the CG modifier. The Date of Submission is relevant here. The only claims that you should be holding are those where the QVL was not viable until October 1, 2016 (those previously listed in "red") when the CMS system is updated. Otherwise, you should have been submitting claims all along.
Use of the CG modifier on claims SUBMITTED on or after October 1, 2016 should facilitate smoother processing and elimination of some of the rejections that were occurring.
I encourage you to read the entire document linked above as I think this SHOULD answer many/most of your questions.