Billing Telehealth Incident-to a Physician

On March 30, 2020, the Centers for Medicare and Medicaid Services (CMS) issued an interim final rule titled “Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency“. In this interim final rule, CMS did add CPT codes that are typically billed by physical therapists (PTs), occupational therapists (OTs) and speech-language pathologists (SLPs) as covered telehealth services; however, they did not add PTs, OTs and SLPs as telehealth providers.

This led many to ask why would CMS add these CPT codes to the list of covered therapy services if they did not add PTs, OTs and SLPs as telehealth providers? This is because the Medicare program allows physicians, physician assistants, nurse practitioners, and clinical nurse specialists who is licensed or certified by the state to furnish therapy services can bill the CPT codes that were added to the list of covered telehealth services.

A second question that arose was can a physical therapist or occupational therapist who is employed by a physician practice perform a telehealth visit and have that visit billed incident-to a physician. Right now, we do not know the answer to this question and we are seeking clarification from CMS on this question.

Watch for updates if additional information becomes available. For those of you that are a Gold Member to my website, thank you! We appreciate your business and loyalty.