CMS delays billing for certain rural health clinic encounter services

April 6, 2016

Certain changes to Medicare billing requirements may require a delay in payment for some rural health clinic services. We believe the delays in billing will be relatively minor, but are interested in hearing more from those with rural health clinics.

Effective April 1, rural health clinics are required to bill Medicare using the appropriate CPT codes for specific individual services in addition to billing the single code for RHC encounter services. We have heard the new requirements create issues for some hospital billing systems. Please let us know if your rural health clinic is facing operational issues billing under the new requirements. Medicare will pay visits with CPT codes that qualify as RHC encounters at the clinic’s encounter rate.

In late March, the Centers for Medicare and Medicaid (CMS) services expanded the list of codes that qualify for encounter payment to include a number of minor dermatology and orthopedic services often done in primary care clinics. These additional services have not yet been added to the files provided to the Medicare administrative contractors. The list of qualifying RHC encounter services requires clinics to delay billing of the additional codes until October 2016. We have been told clinics need to delay billing these codes only when they are the only code that would qualify the visit as an encounter. No delay in billing is necessary when the code is billed in conjunction with a separate office visit code or other code that qualifies the visit as an encounter.

Please let us know if you believe this will have a financial impact on your rural health clinic. We our also concerned about the impact on clinics’ relations with their Medicare patients if the clinics must delay billing of certain services. Clinics may wish to identify these services and advise patients of the billing delay at the time of services. WSHA has expressed our concerns with both the American Hospital Association and with Noridian and will pass on any additional information we receive.

Washington Hospital Services Industry Partner PARA HealthCare has released a summary outlining some of the changes going into effect with the new Medicare RHC billing requirements. You can read the summary here. To learn more about PARA HealthCare or any of our other Industry Partners, please visit our website or contact Paul Unsworth at 206-577-1806.  (Andrew Busz,


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