Billing Changes Coming to Health Care Services in 2022

By Devin Partida, Editor-in-Chief,
Twitter: @rehackmagazine

The beginning of the 2020s brought a great number of changes to the medical industry as a whole. Telehealth, which was beginning to gain popularity at the end of the 2010s, became a necessity to allow patients to continue their treatment while slowing the spread of COVID-19. The virus is in the process of shifting from its pandemic to its endemic stage, and many of the emergency measures that were slapped into place during the first two years of the pandemic are no longer as functional as they once were.

What billing changes do medical practitioners need to be aware of in 2022, and how will these changes impact both existing and new practices moving forward?

Place of Service (POS) Codes 2 and 10

The COVID-19 pandemic altered many aspects of the medical industry, especially where patient interaction is concerned. While many practices may have shifted to telehealth during the height of the pandemic, most of the patients taking advantage of this service were not new patients, according to information collected by the Office of the Inspector General (OIG). Between March and December 2020, 78% of patients receiving psychiatric telehealth treatments already had an established relationship with the practitioners.

Before January 1, 2022, telehealth practitioners could utilize POS code 2 to classify all telehealth provided to a patient, regardless of where that patient was at the time. Now, that code has been changed and a new code has been added.

POS code 2 now refers to “Telehealth Provided Other than in a Patient’s Home.” POS code 10 is used for “Telehealth Provided in Patient’s Home.” It is important to note that claim adjudication for POS 10 doesn’t start until April 4th and any claims submitted before that date will not be reimbursed.

The No Surprises Act

The No Surprises Act, which went into effect on January 1st, was designed to protect patients from receiving enormous bills after a trip to the emergency room. Two out of every three households worry about being able to afford an unexpected medical bill, and upwards of 50% of them don’t have the means to pay the bills in full.

This sounds like a beneficial change for patients, but it may prove to be problematic for providers and billers. Insurance providers are beginning to use the Act as an excuse to terminate existing high-fee schedule agreements and force providers into lower-rate contracts.

At the time of this writing, groups are working to urge the administration to revise the No Surprises Act to prevent this sort of exploitation by insurance companies, but there have not yet been any updates.

Home Health Notice of Admission

Also beginning on January 1, 2022, billing changes will begin to impact home health providers. These providers will be required to submit at least one Notice of Admission (NOA) type of bill (TOB) 32a as the first bill for any sort of home health services. This NOA covers the next 30 days. Once that is in place, providers must also submit TOB 0329 for each period of care.

A TOB 32a must be submitted within five days of the beginning of care, or penalties, as outlined by the CMS methodology, will be implemented.

Skilled Nursing Facility Billing Update

Skilled nursing facilities have a brief update that went into effect on January 1, 2022. Rather than submitting final bills, Wellcare is taking on the responsibility for adjudicating interim bills for skilled nursing facilities for Medicare participants.

Looking Forward

Most of the changes that went into effect on January 1st, 2022, are fairly minor, like the change to skilled nursing facility billing. Others, like the previously unforeseen impact of the No Surprises Act, are still being explored and will likely continue to change throughout the year.