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Modifier CS and COVID-19 Billing

How should the CS modifier, which removes application of beneficiary cost-sharing (deductible and co-payment), be applied to telehealth services and/or E/M visits?

The CS modifier should be applied for certain E/M services related to COVID-19 testing, whether they are furnished in person or via telehealth.

These services are medical visits for the HCPCS E/M categories described below when an outpatient provider, physician, or other providers and suppliers that bill Medicare for Part B services orders or administers COVID-19 lab test U0001, U0002, or 87635.

Cost-sharing does not apply for COVID-19 testing-related services, which are medical visits that: are furnished between 3/18/2020, and the end of the PHE; result in an order for or administration of a COVID-19 test; are related to furnishing or administering such a test or to the evaluation of an individual for purposes of determining the need for such a test; and are in any of the following categories of HCPCS E/M codes:

  • Office and other outpatient services
  • Hospital observation services
  • Emergency department services
  • Nursing facility services
  • Domiciliary, rest home, or custodial care services
  • Home services
  • Online digital evaluation and management services

Cost-sharing does not apply to the above medical visit services for which payment is made to:

  • Hospital outpatient departments paid under the outpatient prospective payment system
  • Physicians and other professionals under the Physician Fee Schedule
  • CAHs
  • RHC
  • FQHCs

For services furnished on or after 3/18/2020, and through the end of the PHE, outpatient providers, physicians, and other providers and suppliers that bill Medicare for Part B services under these payment systems should use the CS modifier on applicable claim lines to identify the service as subject to the cost-sharing waiver for COVID-19 testing-related services and should NOT charge Medicare patients any co-insurance and/or deductible amounts for those services.

Note: Cost sharing for the line items with the CS modifier will no longer be bypassed effective 5/12/2023.

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Revised 4/10/2023