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7/9/2025 Part B POE Advisory Group Meeting

Meeting Minutes

Meeting Time: 10:00 a.m.–12:00 p.m. ET

Member Attendees: Morris Auster, Dawson Ballard, Doris Barnes, Sheila Bembenek, Madelon Berger, Todd Bergstrom, Louise Bertrand, Kimberly Bischel, Bridget Charrier, Ilka Collier, Renay Coonan, Pam D’Apuzzo, Heather Downey, Darren Goodwin, Deborah Gregoire, Christie Hewson, Stephanie Hirst, Cindy Kennedy, Kevin Kile, Jenny Kovich, Dr. Lloyd Kupferman, Judith Lindeborg, Vera Loftin, Sara Luther, Liz Maas, Jessica Marden, Karen Matarazzo, Kristen McCormick, Natasha Moser, Ashley Mui, Sheila Mulka, Joyce Nurenberg, Cherree Overton, Marcia Pachon, Mark Polge, Nikki Ramiez, Gilbert Rosenblum, Tracy Ross, Debra Rossi, Ken Ryan, Allie Ruffolo, Amy Schaffer, Ekaterina Spirin, Kate Tieppo, Katie Watkins, Katie Werner

National Government Services Associates: James Bavoso, Christine Brauer, Laura Brown, Michelle Coleman, Jennifer DeStefano, Arlene Dunphy, Alicia Forbes, Linda Klug, Lori Langevin, Jennifer Lee, Phyllis McAdams, Carleen Parker, Michele Poulos, Nena Rodrigues, Susan Stafford, Amy Stauffenberg, Gail Toussaint

Agenda

  1. Welcome/Introductions
  2. Opening Remarks
  3. What to Expect 10/1/2025 for Telehealth Services
  4. 2025 Spring Virtual Conference Feedback
  5. Open Discussion
  6. 2025 Meeting Dates

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I. Welcome/Introductions

Lori Langevin, POE Consultant, NGS

Lori welcomed the members to the meeting and thanked them for joining. Lori advised she was the facilitator for the meeting, along with Christine Brauer and Jim Bavoso, our manager. Other POE department staff and NGS staff are also on the call.

Lori stated members should have received the Teams invite with a link to the meeting and an email with the agenda and materials for today’s meeting. Lori advised the group if they could not join via Teams and phoned in, to be sure to let us know so they could be included in the minutes for attending. Lori reviewed the agenda and turned it over to Jim for opening remarks.

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II. Opening Remarks

Jim Bavoso, POE Manager, NGS

Jim welcomed the members, advising there was not a lot to discuss today but we wanted to get together to go over a few items and get feedback from the group. We also have a few additional items we’ll cover during open discussion. Jim reminded the members we rely on them for assistance in what we promote, prepare, and get out to the provider community. He then turned it back over to Lori for the first topic of discussion.

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III. What to Expect 10/1/2025 for Telehealth Services

Lori Langevin, POE Consultant, NGS

Before Lori began with telehealth, she advised members the meeting recording was deactivated for any type of recording tools and should not be an issue going forward and as always, the sessions should not be recorded by the members.

Lori began with a short slide presentation on telehealth discussing what will be happening beginning 10/1/2025. Lori asked if the members were ready as the statutory limitations that were in place before the COVID-19 PHE will begin again for most telehealth services effective 10/1/2025. We have been conducting regularly scheduled webinars on this topic since the inception of the COVID-19 PHE.

We get a lot of questions because many providers never billed telehealth services before COVID-19, therefore It takes ongoing training for those providers to understand how it works. For those who have billed prior to the PHE, it’s not going to be a big issue. There will again be geographic restrictions, location restrictions where you can provide services, as well as the limitation on the scope of practitioners who can provide telehealth services.

For the nonbehavioral or non-mental health visits there will be originating site requirements as well as geographic location restrictions. Providers should be aware of the HRSA Medicare Telehealth Payment Eligibility Analyzer. The originating site is the location of the eligible beneficiary at the time the service is furnished. It can be a rural HPSA located either outside of a MSA, or in a rural census tract of an MSA or county outside of an MSA. When you access the Medicare Telehealth Payment Eligibility Analyzer, you enter the address where the service will be provided, and it tells you if the service is eligible for telehealth payment.

Originating sites remain the same as before with the only difference being the patients’ home is a permissible originating site for services provided for diagnosing, evaluating or treating; mental health disorders, substance abuse disorders and monthly ESRD related clinical assessments.

Telehealth for behavioral or mental health services will continue as it is wherever the patients are located. There are no originating site requirements and no geographic location restrictions.

The Full Year Continuing Appropriations & Extensions Act of 2025 is what’s allowing this to be extended to 9/30/2025. All providers have through 9/30/2025 to continue billing as they have been doing.

There is still the waiver for the in-person visit within six months of an initial Medicare behavioral/mental telehealth service and annually thereafter, also non-behavioral mental health can continue to be delivered using audio only communication platforms. The Extension of Telehealth Access Options reference was provided.

Lori asked if the members were ready for 10/1/2025 and whether they would be affected or if they had changes they needed to make.

Jim also added we have been doing telehealth training for a long time and what we are finding is that there are many providers not aware that this is going to end and there are going to be changes and that is a concern to us. Is there anything you can share with us that you know or that you are hearing? Please unmute yourself and speak up or type your question/comment in the chat.

POE AG Member Feedback

  • Members shared: We are aware. We are watching this and we have a plan in place.
  • A member asked if NGS is aware of anything.
    • Jim advised we have heard there is a bill pending in the house. We do not know if it moved or where it is. We anticipate there will be some action. Will it be timely? We will see. Jim commented that people are asking what can we do? It really does take an act of Congress to make these changes.
  • A member asked if nonbehavioral health will still be audio only October 1st?
    • NGS Response: Audio-only telehealth services are permitted in all originating sites through 9/30/2025. In general, audio-only telehealth services are only permitted if the beneficiary is in their home. All other originating sites are medical facilities that have the infrastructure and broadband capacity to support two-way, audio/video communication technology. Telehealth services for mental health disorders, substance abuse disorder and monthly ESRD-related clinical assessments are the only time the home is permissible after 9/30/2025.
  • A member asked if the in-person requirement for behavioral health could be clarified.
    • Lori stated we asked for CMS clarification on that based on feedback we received as a lot of patients started this during COVID-19, back five years ago, so they want to know how do we get back to that in-person visit? Is it six months from the initial?
  • A member asked if the six month in-person is six months from September 30. What if the in-person took place prior to September 30.
    • Lori indicated if you already had the six months it would be annually from that in-person visit. CMS has not really spelled it out, they keep saying the waiver is continued but after 10/1/2025, you go back to how you were doing it before COVID-19. CMS has also stated there are exceptions to the in-person visit for patients who already get telehealth behavioral health services and have circumstances where an in-person care may not be appropriate. We hope to ger more clarification on those circumstances.
    • Since the waiver is ending 10/1/2025, that means the policy will be in effect 10/1/2025. Therefore, when  providing telehealth for mental health to a patient in their home that patient must have been seen in person within the previous six months. That is within the six months prior to 10/1/2025. It is not within the next six  months or any compilation of how long they have been treating the patient. If they have not seen the patient in person between 4/1 and 10/1 that patient would not qualify for telehealth.
  • A member asked if a patient could sign a waiver and pay for telehealth if they wish?
    • Lori stated we went over this at a previous meeting, we will check and add it to these minutes.
  • A member asked since there are different codes that are statutorily excluded from the MPFSDB, wouldn’t you think if they used those excluded codes for the self-pay option, they would not need an ABN because those codes aren’t even in the MPFSDB?
    • Jim added that we will double check. The problem we hear is the patients say yes, I signed the ABN. The service gets billed and not paid. They then come back to us saying the doctor never told me even though the ABN was signed. We want to double check and make sure we have a proper answer for you. We will get an answer out to all and see what we need to promote as well to the provider community.
  • Another member asked if there were any issues with claims processing with the mental health modifier used by primary care physicians who diagnose and treat for mental health? They believe the primary care doctor who diagnoses mental health is part of the mental health benefit for telehealth.
    • Jim asked, so you have a primary care nonpsychiatric physician treating the patient for a psychiatric service?
      • The member stated they bill the telehealth code they just are not sure if there are claim processing issues now and if they might continue after October 1st because of the no specialty restriction?
    • Lori stated that the only feedback we have received on this is if you are treating that patient for mental health, any mental health type of condition, then you will fall under where you can still do home visits and there wouldn’t be a geographic restriction and things along that line. That is what we have been told. We have not received anything from CMS stating that it is only for specialties like psychiatrists or licensed clinical social workers. CMS has stated that if the patient is being seen/treated for mental health issue, then they would be able to go ahead and continue as they have.
    • Jim added that he did not believe there are currently any edits, but if that changes, we will get that out to you.

Also, just a reminder, we continue to do training on telehealth services, so everyone understands how the process works and what we know thus far. If we receive any information from CMS or if Congress makes changes, we will get that information out there.

We are planning to schedule another telehealth webinar for the end of September. This will ensure that we share the latest information that may affect the changes for October 1st.

Follow-up after the meeting on this question: Can patients sign a waiver and pay for telehealth if they wish?

  • NGS Response Medicare patients cannot sign a waiver to pay out-of-pocket for telehealth services if the service is covered by Medicare.
  • Mandatory Claim Submission Rule: If a provider is enrolled in Medicare and provides a service covered by Medicare, they are legally obligated to bill Medicare for that service. They cannot accept cash payment from a Medicare beneficiary in lieu of billing Medicare.
  • Opting Out of Medicare: The only way for a provider to legally operate as a cash-pay provider for Medicare-covered services is to formally opt out of Medicare. This involves a specific process, including filing an affidavit with their Medicare Administrative Contractor and entering into private contracts with each Medicare patient, stating neither party will seek Medicare reimbursement.
  • ABN: An ABN is used when a provider believes Medicare may not cover a service (e.g., it may not be considered medically necessary), even though it is typically a covered service. The ABN informs the patient that if Medicare denies coverage, the patient will be responsible for the cost. However, the provider is still required to submit the claim to Medicare, unless the patient opts not to have the claim submitted.
  • Noncovered Services: If a telehealth service is not covered by Medicare at all, then the Medicare beneficiary can pay out-of-pocket for that service. It is crucial for providers to be clear about which services fall into this category, and which are simply deemed "not medically necessary" in a particular instance (where an ABN might be required).
  • The items on the telehealth list have been reviewed and determined by CMS to be medically appropriate to be provided via telehealth. Documentation would also have to show how providing the service via telehealth meets medical efficacy for the procedure. All of this would need to be determined by legal counsel.

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IV. 2025 Spring Virtual Conference Feedback

Jim Bavoso, POE Manager, NGS

As you know, we conduct two very large virtual conferences each year, one in the Spring and another in the Fall. We ask you and the provider community for topics. We look at claims data, appeals data, and phone call data to help determine what we are going to offer. On the Part B side, we did a three-day virtual conference from 6/3–6/5/2025. We had over 10,000 people registered and over 7,100 attendees (70%). Attendance was very good, and we had a very successful conference. This conference consisted of compliance type issues. Jim shared the session names, attendee numbers per session, what contract the attendees were from (J6, JK) and other areas. We tend to get others outside of our jurisdictions that just come to learn. The sessions with the largest attendance included: evaluation and management, global surgery, critical care, incident to, NCCI and medical necessity, and ABNs. The survey feedback was very positive.

Give me a show of hands how many attended one or more of these sessions? Roughly 20% of the attendees on this call attended. Please be honest and provide feedback on some questions.

Were you satisfied overall?

  • One member indicated they went to a lot of the sessions. They learned a lot. The sessions were very good. They went to sessions they attended before and learned a lot of new things this year.

Jim added, sometimes things change every year and sometimes they don’t. We have about half a million active Part B providers in our 10 states and we try to reach them all, sometimes we need to repeat the information.

Was there anything you would like to change?

  • No members commented.

Was there any one topic that stood out more?

  • A member mentioned incident to service and they learned more than any other session.
  • Another member said the documentation presentation and thought it was great information. The speaker was great and he thanked NGS for having that session.
  • Another member stated they listened to a few sessions and liked critical care. They didn’t learn anything new however, it confirmed what they preach on an ongoing basis from the compliance offices. A lot of people on their team also attended.

Jim asked about the timing, stating we used to do April and May and early June. Going forward do you see any conflicts with the early June timeframe or time of day? We have tried later times in the evening or earlier in the day and they are not very well attended.

  • A member stated June was a crunch month for them especially toward the end of the month. Also, later afternoon would work better for them and not on Wednesdays, which is not a good day where they work.

Jim said we will see what we can do and see what works the best for the majority. We will be preparing for our fall session. We try to tie it to when the Medicare Final Rule is published in November, so we moved our virtual conference to early December. We are in the early stages and wonder what topics or themes you might like to see included.

POE AG Member Feedback

  • I like compliance topics for billing G2211 and the other newer G-codes that came into play in 2024 like patient navigation and other new services. Who can do them and what documentation is needed.
    • Jim stated we have done those sessions. We will dust them off and try to do them again before the next virtual conference. For G2211, we are working on a podcast. Once that is completed and ready to be published, we will let you know. We also have YouTube videos out there on patient navigation and those other G-Codes.
  • Another member stated for code G2211 they didn’t feel they have seen what was originally put out there and the primary care piece of that is very difficult to know if there is any expectation, I mean every primary care doctor thinks they are going to have a long-term relationship with that patient. But even if it’s a very healthy person that comes twice a year, that’s where we run into trouble with it. By everything I read, I think they can bill. We are concerned though that it’s allowed and then we get audited and have money taken back even though they say there is no specific documentation.
    • Jim indicated we can see if we can do something sooner on that topic.
  • Another member agreed with the PIN codes, compliance and G2211. But they would like to get into the “weeds” more than a beginner. Many of them are looking to NGS and CMS to make solid statements as to what is needed. Also is there any opportunity to look at the auditing process? How to approach it, what is CMS looking at, how can we mirror that?
    • Jim noted we do TPE sessions currently, but we can see what we can come up with.
  • A member asked for modifiers and when to use them and not use them. For example, with podiatry toe digit modifiers and the 59 and X modifiers.
    • Jim stated we do have podiatry sessions where we go over those modifiers and NCCI sessions so modifiers in general we will do.
  • Another member suggested the IPPE and AWV, and a checklist as there are so many requirements.
    • Jim indicated we do a bunch of those sessions, but we will take it back as well.
  • A member added more information and documentation on the G0454 code.
  • Another member stated the virtual conference was excellent and just wanted to remind the group and make everyone aware that the OIG is working on incident to in their work plan.
  • A member suggested we go further or more in depth into topics. Can we have a miscellaneous session to cover ideas not covered or what more do you want to know?
    • Jim said to send those questions. We also do let’s chat sessions and open them up for questions. The concern we have is every one of those lets chat or ask the contractor sessions turns into E/M billing. They are mostly the questions we have answered very often or are questions on our FAQs on the website.
    • Jim added if you think of anything else, please let us know. We plan to conduct our next virtual conference in early December, and we will include the Final Rule.
    • If you have specifics, please send them to us. We gather all the questions and continue to update them. We can add them to our documents, webinars, articles and Email Updates.
  • A member added they believe they can give us direction or be helpful with these.
    • Jim stated to please let us know what you need. We will incorporate those questions and ideas. We want to hear positive and negative feedback. We understand there is a lot of turn-over in offices and sometimes they say it is over their head.
  • Another suggestion was more education, documentation and clarification for assistant surgeons and co-surgeon services.
    • Jim stated they must document what the assistant does and what the surgeon does, but we will get more clarification on that.
  • Another suggestion is to review LCDs.
    • Jim advised we have done some of those and they were not well attended. He suggested the member put together a list of specific LCDs or specialties they might like to see, and we can take a look and try them again. A lot of sessions/webinars we do are based off data and questions we receive. Any ideas you have, please send them to us. You don’t have to wait for the next meeting to do that.
  • Another member suggested to do 101 sessions and more advanced sessions on day 2–3 on the same topic.
    • Jim indicated we have done those in the past but can look at that again.
  • Another member asked if it was possible for attendees to have the questions available to them for the let’s chat or ask the contractor sessions.
    • Jim said we will look at that and see if we can improve on it.

Lori reminded members that we will be having a Care Management Week in September again and Jim added that information into the chat.

Lori also mentioned CMS has FAQs on G2211 and NGS also has FAQs on our website.

Jim listed the care management topics in the chat and added the dates for the repeated by popular demand topics of global surgery and incident to.

One other item we have before open discussion is changes coming to the IVR. Phyllis McAdams spoke to the group about the changes. Before she started, Phyllis asked if any members currently use our IVR, no members indicated IVR usage.

Phyllis shared the changes are minimal. You’ll hear a new voice, some functions have changed and some have moved away from the IVR. When you use the IVR, instructions are provided throughout the call. All the information on the new IVR platform and updates will be communicated through our email updates. Phyllis asked if members were interested in assisting us with testing the IVR, let Jim, Lori or Chris know. Lastly, instead of using the IVR, we encourage providers to use our free, secure, web-based NGSConnex portal for your self-service needs. We do offer a number of NGSConnex webinars each month and we encourage you to register for those as there is a lot of information available.

Jim added, with technology as it is now, not many providers utilize the IVR, but we still have it for those smaller practices that do.

No member feedback was received at this time.

Jim mentioned NGS made a change to the written general inquiries coming to us because we were receiving a lot of outsourcing inquiries for ridiculous things and our inventory was very high. So, effective May 2025, we only accept a written general inquiry through the use of our online portal NGSConnex. We will no longer be taking a hard copy. Has this affected anyone?

Jim mentioned to the group that subcontractors of billing or clearinghouses have used this as documentation for the work they are doing and it is really nonsense work. We are trying to combat this. If you hire a clearinghouse or billing company make sure you ask who they subcontract with as they could be an offshore company. Please be very careful since they will be working with your claims data.

No member feedback was received at this time.

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V. Open Discussion

Lori Langevin, POE Consultant, NGS

Lori advised NGS was once again partnering with Performant, the RAC Contractor for RA Region 1 JK and RA Region 2 J6. We will be having two webinars, August 13 and October 15 where they will review the RAC process from beginning to end. Then on December 17 we’ll have a fireside chat, like our let’s chat sessions. We did that last year and got a lot of great questions and feedback. Performant was able to answer all the providers questions and concerns. We want you to be aware of these sessions and to please mark calendars for these dates. We encourage you to attend, especially if you have any questions on RAC reviews.

A member asked if we had any information on short stay review for QIOs. Jim advised that is Part A and this meeting is Part B. However, the Part A group will have information posted on the website and will be doing some webinars on this.

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VI. 2025 Meeting Dates

Lori Langevin, POE Consultant, NGS

  • 9/17/2025
  • 12/17/2025

Lori also reminded the group that the agenda document included NGS upcoming webinars and CMS latest and greatest information and publications. Lori thanked everyone for their participation and feedback and the meeting adjourned.

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Posted 8/12/2025