2023 Update on Telehealth

December 26, 2022
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Rick Gawenda
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Due to passage of the Consolidated Appropriations Act, 2023, the Centers for Medicare and Medicaid Services will reimburse for outpatient therapy services provided by physical therapists, occupational therapists and speech-language pathologists delivered via telehealth in all outpatient settings through

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  1. To clarify, barring another extension of the PHE, this does not change the current rule wherein if provided directly (not incident-to) by a therapist, it will not be reimbursable after June 11, 2023?

  2. Hi Rick,
    Are there any specific documentation requirements that need to be included in therapy notes for Part B telehealth patients? Documentation such as why the services are being provided via telehealth instead of in person? For example, to limit patient exposure to COVID-19, etc? Thank you!

  3. Hi Rick,
    Are there any specific documentation requirements that need to be included in therapy notes for Part B telehealth patients? Documentation such as why the services are being provided via telehealth instead of in person? For example, to limit patient exposure to COVID-19, etc? Or do they have to fall under specific requirements to qualify to be treated under telehealth vs in person?

    1. Yes, there are certain things a therapist should document in the medical record when providing telehealth services. Due to liability reasons and possible state specific issues, this is not something I provide in this format.

  4. I am being told that this extension through 12/31/24 only includes professional billing and does not include Hospital-Based Outpatient Department (HOPD) billing. Is this true? I have not been able to find any documentation to verify this.

      1. This is the reference I was given: chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.cms.gov/files/document/physicians-and-other-clinicians-cms-flexibilities-fight-covid-19.pdf

        They specifically referenced this sentence (pg 5): “The waiver of these requirements expands the types of health care professionals who can furnish distant site telehealth services to include all those who are eligible to bill Medicare for their professional services.”

        I am told this is due to the Hosptials Without Walls ending.

        If HOPD cannot bill telehealth services this would be a massive negative impact to patient healthcare services.

        Thanks for your input.

        1. Do you agree that with ‘Hospitals Without Walls’ ending it also means that Hospital-based Outpatient Department billing will no longer be included for OT/PT/SLP Telehealth reimbursement?

          1. Hospitals without Walls and telehealth are 2 separate and distinct items and do not mean the same thing.

  5. Is there information stating hospital-based services are included in the extension through 2024? Our compliance office has stated that this extension only applies for private practice (“professional billing”) services.

    1. APTA interprets the Consolidated Appropriations Act telehealth extension to apply to all outpatient therapy settings.

    1. You would need to check with the specific insurance carrier the patient has for their insurance.