RHC Billing

RHC (Rural Health Clinic) billing has seen significant changes in 2016. After years of seemingly consistent billing rules and regulations, the last eight months have seen multiple changes in the fundamental way in which RHC services are billed, as well as services that can be provided.

While these billing changes may not have affected your RHC from an operational perspective, the chances are better than average that your operational outlook has changed in the way that you provide RHC services. A few of the 2016 changes include the introduction of CCM (Chronic Care Management) services to the RHC environment, ACP (Advance Care Planning), an update to the RHC preventative services matrix, and a fundamental change to the billing of RHC services on the UB-04 – the April 1 requirement of HCPCS codes for each service provided within the RHC.

The base definition of an RHC visit has not changed. IOM 100-02 Chapter 13, Section 40 continues to generally define a RHC visit in the following terms:

• A medically-necessary medical or mental health visit, or a qualified preventive health visit
• The visit must be a face-to-face (one-on-one) encounter between the patient and a physician, NP, PA, CNM, CP, or a CSW during which time one or more RHC or services are rendered
• A Transitional Care Management (TCM) service can also be a RHC visit

Included among the changes that have been made during 2016, CMS has provided a list of qualifying visits for RHCs. The CMS list of qualifying visits for RHCs located on their RHC web page at https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/FQHCPPS/Downloads/RHC-Qualifying-Visit-List.pdf is not an all-inclusive listing. You must still rely on the base definition of an RHC visit.

Here are some quick references as you continue to provide healthcare services within your RHC and navigate the extensive listing of CMS regulations and billing requirements.

 

• CMS RHC Reporting Requirements FAQs  (https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/FQHCPPS/Downloads/RHC-Reporting-FAQs.pdf)

• MLN Matters SE1611  (https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/SE1611.pdf)

• RHC Medicare Benefit Policy Manual  (https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c13.pdf)

• RHC Preventative Services Chart  (https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/FQHCPPS/Downloads/RHC-Preventive-Services.pdf)

• CCM MLN MM9234 and FAQs  (https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM9234.pdf) and  (https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/FQHCPPS/Downloads/FQHC-RHC-FAQs.pdf)