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Are FQHC, RHC and Indian Health Services (IHS) claims required to have medical justification as either a remark on the claim or as an attachment to the claim?

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Are FQHC, RHC and Indian Health Services (IHS) claims required to have medical justification as either a remark on the claim or as an attachment to the claim?

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Yes. Medical justification is required as either a remark on the claim or as an attachment to the claim for all excluded optional benefits. The medical justification is in the Remarks field (Box 80) on the UB-04 claim form, or in the NTE segment in the 837 Institutional 4010A1 electronic claim format, or as an attachment to the claim. Optional benefit provided to EPSDT-eligible beneficiaries, Medicare/Medi-Cal “crossover claims” and services rendered by a physician do not require medical justification. Please review the Optional Benefits Exclusion Policy: Additional Billing Information for FQHCs, RHCs and IHS article for detailed information about the medical justification requirements for these facilities.

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