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News & Press: COVID-19

COVID-19: Correcting telehealth services billed with POS 02

Wednesday, July 29, 2020   (0 Comments)
Posted by: Elissa Rodrigues
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On March 6, 2020, the Centers for Medicare & Medicaid Services (CMS) broadened access to Medicare telehealth services during the COVID-19 public health emergency (PHE). This allows beneficiaries to get a wider range of services from their doctors and other clinicians without traveling to a health care facility. These guidelines are effective for dates of service (DOS) on and after March 1, 2020, until the end of the designated PHE.



Providers were instructed to bill professional claims for all telehealth services with DOS on and after March 1, 2020, and for the duration of the PHE to Medicare with:


  • Place of service (POS) equal to what it would have been had the service been furnished in-person (example: POS 11 for office)
  • Modifier 95 applied to claim lines for services furnished via telehealth

This instruction differed from standard instructions to bill telehealth services with POS 02. Billing claims with POS 02 applies a facility differential to the payment.



To correct the payment differential, providers can request an appeal of the paid claim to revise the POS and add modifier 95, based on the instructions above. This option is available for only telehealth services furnished on or after March 1, 2020, and through the duration of the PHE.


Provider action

Providers can request an appeal for claims with dates of service on or after March 1, 2020, previously processed with POS 02 and paid at the facility differential rate, to correct the POS and add modifier 95 to claim lines for telehealth services. This will allow the claim lines to price at the same rate as if the services were provided face-to-face.

This appeal must be requested in writing. Providers can request the appeal of a Part B claim through the following methods:

  • Submit your completed form via fax pdf file
  • Submit your appeal via the redetermination function pdf file through the Secure Provider Online Tool (SPOT).
  • When requesting an appeal, you must specify the reasons you disagree with the initial determination.
  • When completing the fax form, indicate in the additional narrative "Revising billing related to COVID-19 telehealth claims"
  • When requesting via the redetermination function through the SPOT, indicate in the reason for the request "Revising billing related to COVID-19 telehealth claims" and be specific about what you want changed per detail line.


Source: First Coast Service Options, Inc.