NGS - COVID-19 Testing as it Relates to the Terminal Illness
NGS position is that the COVID-19 testing is related to the terminal illness and the GW modifier is not appropriate. Hospices should, therefore, provide payment to the lab. The rationale is that the hospice is responsible for the management and palliation of the terminal illness and related conditions. The test results provide the hospices with the COVID-19 status of their beneficiaries and guide the management and palliation of the terminal illness and related conditions, for example in nursing facilities to determine location (e.g., floor) and staff that provide care for beneficiaries with and without COVID-19.
Hospices cannot bill Medicare for the technical component of COVID-19 testing. Only labs or providers with CLIA numbers can bill the technical component to Medicare. Hospices would pay the technical component out of their per diem. No claim would ever be submitted for the technical component.
Only for the patient’s attending can the professional component be billed to Medicare. If the patient’s attending is employed by the hospice, the hospice can bill the professional component (specimen collection) of the test on the hospice claim. If it is an independent attending physician furnishes the test, he/she bills the professional component of such services to the A/B MAC (Part B) on a professional claim and looks to the hospice for payment for the technical component, from the hospice’s per diem.