Modifier CS and Modifier 95 Definition (2025)

COVID-19 cases are the highest in numbers for most of the hospitals in 2020-21. If you are in the Medical Billing industry you have known some of the most latest changes in billing codes for Telehealth Services and COVID-19 testing codes when do billing for Medicare.

The Families First Coronavirus Response Act (FFCRA) and the Centre  Medicare and Medicaid Programs (CMS),Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency Interim Final Rule affect Medicare Part B payments during the COVID-19 pandemic.

The two laws were passed that state that Medicare and commercial insurance plans cover these services without any cost sharing requirements or prior authorization or other medical management requirements.

COVID-19 codes modifier CS and Modifier 95

Modifier CS

The Families First Coronavirus Response Act  FFCRA waives cost-sharing for COVID-19 testing-related services for Medicare Part B patients. Medicare and privately purchased insurance will pay 100% of the claim Cost-sharing is waived for office visits that result in the order or administration of the COVID-19 test, or E/M visits to determine the need for such a test. The cost-sharing waiver facility is effective for dates of service (DOS) starting 03-18-2020-Till the end of the public health emergency.

.Although the information about the modifier was released in April, it is retroactive to March 18, 2020.

Modifier -95

The Interim Final Rule updates payment policies to allow physicians to be paid at the non-facility rate for Medicare Telehealth services during the COVID-19 panedemic. Medicare will pay the non-facility amount for Telehealth Services when they are billed with the place of service (POS) the physician would have used if the service had been provided in person (Ex- Place of service 11 – Office Visit). Physicians should append modifier “95” to the claim lines delivered via Telehealth Services. Claims with POS-02 – Telehealth will be paid at the normal service rate, which is less than the non-facility rate under the Medicare physician fee schedule.

Modifier CS can be used on both in-person visits and via Telehealth services. If using modifier 95, for telehealth services then report a code like this : 99214 -CS -95.

Modifier CS affects the payment, so using it in the first place before 95 and  Modifier 95 is informational.

Telehealth and Corona Modifiers

SERVICEPLACE OF SERVICEMODIFIERS
Office visit related to COVID-19 testingPOS11 – Office Visit-CS
Telehealth visit related to COVID-19 testingPOS11 – Office Visit-95, -CS
Office visit not related to COVID-19POS11 – Office VisitN/A
Telehealth visit not related to COVID-19POS11 – Office Visit-95
Virtual Check-In (HCPCS G2012, G2010)POS11 – Office VisitN/A
E-Visit (CPT 99421-99423)POS11 – Office VisitN/A
Telephone Evaluation and Management (CPT 99441-99443)POS11 – Office VisitN/A

Can we append a modifier to the G2012 CPT?

CPT G2012 and CPT 2010 are virtual communication HCPCS codes. These codes are not considered at Telehealth CPT codes. The following guidelines follow on these CPT codes

  • CPT G2012 and G2010 HCPCS codes were developed by CMS for virtual communication.
  • Do not use POS-02 or modifier 95 on these CPT codes for Medicare claims because these are not considered telehealth services.
  • CPT G2012 and G2010 HCPCS codes are not on CMS’s list of telehealth services and do not use real-time, interactive, audio/visual communication
  • These require verbal consent, a single consent can be obtained for all communications based technology services annually.

CMS developed two new HCPCS codes G2010 and G2012 for 2019 to pay a very small amount for a virtual check-in and for reviewing an image or recording, “store and forward.” 

Referring Links

For more information Telehealth Services is available on the American Academy of Family Physicians’ (AAFP)