Billing Telehealth Incident-to a Physician: UPDATE

April 14, 2020
Rick Gawenda

During a Centers for Medicare and Medicaid Services (CMS) “Office Hours” call on April 14, 2020, I had the opportunity to ask CMS if a physical therapist or occupational therapist employed by a physician practice can provide a telehealth visit and have that telehealth visit billed incident-to the physician (under the physicians NPI in Box 24J on the 1500-claim form)?

The answer from the CMS representative was

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  1. but they added us as telehealth providers under their interim ruling. but not distant site providers. so shouldn’t we still be able to do incident to?

    1. CMS DID NOT add PT’s, OTs and SLPs as telehealth providers. They added CPT codes used by PTs, OTs and SLPs.

      1. In light of the PHE for the COVID-19 pandemic, we believe that the risks associated with confusion are outweighed by the potential benefits for circumstances when these services might be furnished via telehealth by eligible distant site practitioners. We believe this is sufficient clinical evidence to support the addition of therapy services to the Medicare telehealth list on a category 2 basis.

        Wouldn’t this mean we are Telehealth providers?

          1. yes. hence the confusion. We/our services are added to the Telehealth approved services, but they are not providing payment. so should we not be able to still perform these services and then bill incident to in order to bill appropriately for these services? Based on the answer CMS gave above in this article contradict their ruling in the interim ruling that the put out a few weeks ago.

          2. They did not contradict their ruling. It’s a 2-step process. Process 1 is adding CPT codes to the approved telehealth list. That is now completed. Step 2 is adding PTs, OTs and SLPs as a telehealth provider. That is not done yet as of today. There is nothing more I can say on this subject. The horse is dead!