CMS Updates Instructions for RHC/FQHC Billing of Hospice Attending Physician Services

Beginning January 1, 2022, to receive the Rural Health Center (RHC) All-Inclusive Rate (AIR) or Federally Qualified Health Center (FQHC) Prospective Payment System (PPS), the RHC or FQHC must report the GV modifier (attending physician not employed or paid under arrangement by the patient’s hospice provider) when a physician, Nurse Practitioner (NP), or Physician’s Assistant (PA) employed by or working under contract with an RHC or FQHC furnishes hospice attending physician services to a beneficiary that has elected hospice.

Congress authorized RHCs and FQHCs to bill Medicare for hospice attending physician services provided by a physician nurse practitioner (NP) or physician assistant (PA) who is employed by the facility and is the patient’s designated attending physician. (See the August 19, 2021 NAHC Report for more information.) The Centers for Medicare & Medicaid Services (CMS) has updated Change Request (CR) 12357 to implement the GV modifier to report on claims when billing for these services.

Hospices may wish to alert RHCs/FQHCs to this CR.

Please note that:

  • RHCs must report the GV modifier on the claim line for payment (that is, along with the CG modifier) each day a hospice attending physician service is furnished.
  • FQHCs must report the GV modifier on the claim line with the payment code each day a hospice attending physician service is furnished.
  • The hospice attending physician services are subject to coinsurance and deductibles on RHC claims and only coinsurance on FQHC claims.

When the RHC/FQHC furnishes a hospice attending physician service that has technical component, the provider furnishing the technical component would go to the hospice for payment as discussed in the Medicare Claims Processing Manual at https:/www.cms.gov/Regulations-andGuidance/Guidance/Manuals/Downloads/clm104c11.pdf.

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