Provider Notice Issued 01/09/2023

Date:   January 9, 2023

To:       Enrolled Community Mental Health Centers; Behavioral Health Clinics; Physicians; Licensed Clinical Psychologists, and Licensed Clinical Social Workers

Re:      Rate Adjustments and Telehealth Billing Guidance

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This notice provides guidance related to rate adjustments for service dates from January 1, 2022, through May 5, 2022. It also explains two telehealth modifier system issues that have been resolved and require action by providers. The guidance in this notice applies to fee-for-service (FFS) claims only.

Issue #1 - Rate Adjustments January 1 through May 5, 2022
By provider notice dated January 3, 2022, the Department of Healthcare and Family Services (HFS) informed providers of a rate increase effective with dates of service beginning January 1, 2022, pending approval by the Centers for Medicare & Medicaid (CMS). After approval by CMS, the Community-Based Behavioral Services Fee Schedule was updated May 5, 2022. Claims that were billed and paid between January 1 and May 5, 2022, were paid at the lesser rates.

Issue #2 – Telehealth Modifier System Issue – Duplicate Denials
HFS recently completed system updates regarding modifiers "GT" and "93" to allow payment on service lines that initially rejected as duplicate services. Claims that were billed with dates of service beginning October 1, 2021, for a service with modifier "GT", or with dates of service beginning July 1, 2022, for a service with modifier "93", and a service without modifier "GT" or "93" for the same customer, same date of service, and same procedure code prior to the recent system updates experienced D01 – Duplicate Payment Voucher denials.    

• Modifier GT – identifies telehealth interactions using both audio and video telecommunications systems. 
• Modifier 93 (Effective with dates of service beginning July 1, 2022) – identifies telehealth interactions using an audio-only telecommunications system.

 
The system updates allow providers to bill a service with modifier "GT" or "93" and a service without modifier "GT" or "93" for the same customer, same date of service, and same procedure code and get reimbursed for both services.

Issue #3 – Telehealth Modifier System Issue – Non-Payment of Applicable Add-ons
HFS has completed the system update regarding payment of applicable add-ons when the service is billed with the "GT" modifier. Claims that were billed with dates of service between October 1, 2021, and December 28, 2022, with modifier "GT" prior to the recent system update experienced non-payment of the applicable add-on.

Resolution
As these three issues overlapped within the same timeframe, HFS will not be able to complete adjustments for the rate increase and reprocess denied telehealth claims due to the complexity in identifying claims requiring adjustment. Additionally, many providers continued to use the former state maximum rate prior to publication of the increased rates as the charge on a claim; therefore, the charge amount is not high enough to benefit from an adjustment.

• For Issue #1 – Providers should submit replacement claims for services from January 1 through May 5, 2022, that are eligible to be paid at the increased rate. Replacement claims (claim frequency/bill type '7') are considered timely if submitted within one year from the original voucher date and require only one 837P transaction (a replacement claim both voids the original service and replaces it with a new claim). Detailed instructions for replacement claim submittal is found in the Chapter 300 Companion Guide for 837P transactions.

• For Issue #2 - Providers need to rebill any telehealth claims that originally denied as a duplicate due the modifier issue outlined above. Providers will have 180 days from the date of this notice to rebill. Providers may request timely filing overrides, when applicable, by contacting a community mental health billing consultant at the number below.

• For Issue #3 – Providers should submit replacement claims for services between October 1, 2021, and December 28, 2022, which are eligible for an add-on, though the add-on amount was not paid. Replacement claims (claim frequency/bill type '7') are considered timely if submitted within one year from the original voucher date and require only one 837P transaction (a replacement claim both voids the original service and replaces it with a new claim). Claims that are more than one year from original voucher date will need to be voided (claim frequency/bill type '8') and rebilled using claim frequency/bill type '1' for an original claim. Detailed instructions for replacement and void claim submittals are found in the Chapter 300 Companion Guide for 837P transactions.
  

Note:  Providers may not "roll up" units for telehealth billing unless there is an exact match on the telehealth Place of Service (02 or 10) and Modifier (GT or 93) for the service. Providers should direct requests for timely filing override on FFS claims to a community mental health center billing consultant in the Bureau of Professional and Ancillary Services at 877-782-5565, option sequence 1, 2, 4, then 8. Managed care questions should be directed to the applicable HealthChoice Illinois managed care plan.
 

Kelly Cunningham, Administrator

Division of Medical Programs