Can Hospital Therapy Departments Provide Telehealth Services
This article was updated on May 21, 2020. See below for updated answers.
On April 30, 2020, the Centers for Medicare and Medicaid Services (CMS) temporarily expanded who can provide and be paid for telehealth services under the Medicare Part B program to now include physical therapists, occupational therapists and speech-language pathologists. It was clear that this expansion of telehealth services included therapist-owned and physician-owned private practices but were unclear if this also included hospital outpatient therapy departments. Well, as of May 5, 2020, we now know the answer.
Question
Can a hospital outpatient therapy department be paid for a telehealth visit when provided by a physical therapist, occupational therapist, or speech-language pathologist?
Answer
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Question
Is there a way for a hospital to provide physical therapy, occupational therapy and/or speech therapy to a Medicare Part B patient remotely and bill those services to the Medicare program?
Answer
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Question
How do you add a Medicare beneficiaries home as a provider-based department (PBD) of your hospital?
Answer (Updated May 21, 2020)
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Question (Added May 21, 2020)
Must hospitals use condition code DR on the UB-04 claim form when providing services remotely to a Medicare beneficiary in their home?
Answer
Yes, hospitals would use condition code DR since this expansion is due to a CMS Waiver as a result of the Public Health Emergency due to the COVID-19 pandemic.[/mepr-show]
Question
What type of telecommunication system must I use when providing physical, occupational and speech therapy remotely to a Medicare Part B beneficiary?
Answer
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Question
Isn’t delivering the therapy services remotely really telehealth services?
Answer
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Question Added May 13, 2020
What modifier(s) do I append to the CPT codes on the claim form?
Answer (Updated May 21, 2020)
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Question Added May 13, 2020
Must I use Condition Code DR on the UB-04 claim form?
Answer
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Question Added May 13, 2020
Must the physical therapist, occupational therapist or speech-language pathologist be in the hospital when providing the visit through telecommunication technology or can they be at their home?
Answer
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Question
Are all the documentation, billing and payment rules and regulations the same when providing services remotely as they are for an in-person visit?
Answer
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Question Updated May 13, 2020
Does this apply to critical access hospitals?
Answer
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I hope you found this article helpful. If you have additional questions related to hospital outpatient therapy departments treating Medicare Part B patients in their home using telecommunication, write your question out below in the comment box and if applicable and appropriate, i will add it to this article. As always, thank you for being a Gold Member!
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If we are billing in this fashion, would we still have to only bill the CPT codes which Medicare has allowed for telepractice, or could we bill any Medicare covered therapy CPT codes?
Since this is not considered telehealth, you could bill any applicable and appropriate CPT code.
Can you clarify the question “Does this apply to critical access hospitals?”. Your answer was no. Do you mean that a critical access hospital has the ability to perform telehealth services? Thanks
CAHs can’t do telehealth for OP therapy.
But we believe they can see patients remotely by adding the patient’s home as a Provider-Based Department. We will try and clarify this with CMS on May 7th.
Our agency is providing telehealth OT/PT & Speech therapy services. Would you have any billing updates on Outpatient Rehab Facilities (bill type 074X)? We bill on the UB04 as a part A provider. Thank you.
Please read this article for the answer to your question.
https://gawendaseminars.com/cms-adds-therapists-as-telehealth-providers/
Are there CMS updates or anything in writing to support the information from the CMS “Office Hours” call on May 5, 2020, to state that telehealth billing for outpatient therapy services applies only to those in the private practice setting, both therapist owned and physician owned? I am unable to find any information that speaks directly to this.
CMS will eventually post the recording and transcript of the May 5, 2020 “Office Hours” call on their website. Once available, I will link it to this article.
Thanks for the update. Questions:
1. What about rehab agencies that provide outpatient physical therapy services in a private practice type setting but bill using UB-04? Can those rehab agencies also add the beneficiary’s home as a PBD?
2. If no, do you foresee CMS making an update in the future to add rehab agencies (that offer outpatient services) as providers of telehealth? I’m just wondering what options we have as a rehab agency, as it appears to be none right now.
1. No
2. No
Thanks. Does a governor’s mandate supersede this? In other words, if the governor mandates telehealth physical therapy services to be paid the same rates as in person therapy, the type of billing form would no longer matter, correct?
Governor mandates do not apply to federal insurances.
Just to clarify, does a separate email for PBD need to be sent to CMS for each individual patient?
I would suggest you ask your CMS Regional Office that question as well as work with your Hospital Administration if you are going to be adding Medicare beneficiaries homes as provider-based departments of the hospital.
As usual your up to date information is so very helpful.
As a CAH and serving a wide spread older population this is such a Catch-22.
Katesel Strimbeck PT, MS, MHA
We hope to clarify about CAHs during the CMS “Office Hours” call that begins at 5:00pm EDT.
How would you recommend billing for an inpatient PT evaluation performed via an ipad on a Covid-19 positive patient? The patient and therapist were in the same building, but the therapist stayed outside the Covid unit with the RN in the unit assisting the patient.
Read Question #9 on page 26 of this document:
https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf
Does this refer to Medicare part A?
Under Medicare Part A for inpatient acute care, you do not bill CPT codes, rather, are paid via DRG’s. Since the patient is admitted into your hospital, you would not add their home as a hospital provider-based department.
We are a licensed hospital in the state of PA, certified by Medicare and excluded from IIPPs and we bill PT/OT and ST services as an outpatient department of the hospital under the Physician’s Fee Schedule.
We are currently responding to the needs of our patients and performing PT/OT/ST services through the use of audio/visual technology in their homes. Are Inpatient Rehabilitation Facilities, billing under the Physicians Fee Schedule as an Outpatient Department of the Hospital, with bill type 131, provided coverage for billing these types of services to Medicare? Are Inpatient Rehabilitation Hospitals, falling under the PBD exception rule? If so, are Inpatient Rehabilitation Hospitals required to submit attestation to CMS Regional Office or is this only for Outpatient Departments of the Hospital being paid under OPPS?
Are you a freestanding IRF or is your IRF part of an acute care hospital?
As an extension site of a hospital wouldn’t all Joint Commission and State standards apply for recognition as a provider based “department”? Wouldn’t this require site surveys, life safety policies, etc? If so, I cant see how this would ever be practical.
That would be a question to ask the JC and will they be lax in there requirements during the PHE due to COVID-19.
We are getting some denials from Medicare (Texas) for G2063 because we applied the GP modifier. Are you hearing this from anyone else?
Yes and CMS is aware of the issues.
Hello Rick, Can you clarify, based on the recent CMS “updates”..I understand that if we are a hospital-based outpatient therapy department that bills on a UB-04 form, we still cannot bill telehealth services , but are we allowed to add the beneficiary’s home as a PBD and bill through a UB-04 claim form?
Yes. I would recommend you read this article and work with your hospital administration team on this as this is not something a department should do on their own with the approval of your administration.
We are an outpatient hospital based facility billing on a UB-04.
Can you please clarify the answer regarding that qualifies as telecommunications technology in the Q and A below, copied from above:
Question
Is there a way for a hospital to provide physical therapy, occupational therapy and/or speech therapy to a Medicare Part B patient remotely and bill those services to the Medicare program?
Answer
Yes! A hospital outpatient therapy department can provide outpatient physical, occupational and speech therapy services through telecommunications technology, in a temporary expansion location, which may include the beneficiary’s home so long as it has been made provider-based to the hospital.
Thanks.
You need to use technology that provides real-time 2 way audio-visual between you and the patient.
thank you, and this gets billed using the CPT codes that describe the services rendered because this is not considered telehealth?
And the letter mentioned above needs to be sent to CMS in these cases, such that we would not be able to furnish or bill for these services for 120 days afterward?
You have to submit within 120 days of beginning to bill at an expanded PBD. Work with your hospital administration team on this as this is not something a department should do on their own with the approval of your administration.
what modifiers would be used? The APTA put out info that said to use the DR and CR is this correct?
I have added additional questions and answers to this article.
Some insurances (commercial) are asking us to append a revenue code, does that sound accurate for UB04?
Yes, revenue codes are required on a UB-04 claim form. Your billing department should know what to do and be able to assist you.
What is the potential impact to the rest of the hospital outside of the therapy department with adding a patient’s home address as a PBD?
This is a question you will want to have with your hospital management and administration team. You need to think of policies and procedures you will need in place, what will your accrediting bodies (Joint Commission, CARF, etc.). I am sure your hospital attorney’s will also need to be involved.
Hi Rick- Thanks for all the great information and getting on the office hours call with CMS. I’m wading through the logistics and rationale with hospital administration. Can you clarify something regarding PO/PN modifiers listed in the April 30th interim rule? Those are discussed around OPPS claims- but hospital rehab is paid via MPFS, so I’m thinking they would not apply to us? Getting some conflicting info from legal team who reviewed the interim rule.
PO and PN is not required for services paid under the MPFS.