CMS Adds Therapists as Telehealth Providers
On April 30, 2020, the Centers for Medicare and Medicaid Services (CMS) announced they were adding physical therapists, occupational therapists and speech-language pathologists as temporary providers of telehealth services during the Public Health Emergency due to the COVID-19 pandemic. Here is what we know so far.
Question
Can a physical therapist, occupational therapist or speech-language pathologist in private practice provide a telehealth visit and have it paid by the Medicare program?
Answer
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Question – New Question May 6, 2020
Can a physical therapist or occupational therapist employed by a physician-owned practice provide a telehealth visit to a Medicare Part B beneficiary and have it billed incident-to the physician?
Answer
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Question – New Question May 6, 2020
What are the supervision requirements of a physician when a physical therapist or occupational therapist is employed in a physician owned practice, is providing a telehealth visit to a Medicare Part B beneficiary and is having that visit billed incident-to the physician?
Answer
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Question
Is their a retroactive date for physical therapists, occupational therapists and speech-language pathologists to submit claims for telehealth services provided prior to April 30, 2020?
Answer
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Question
If a Medicare beneficiary paid cash for a telehealth visit, would I need to refund the Medicare beneficiary and submit the claim to my Medicare Administrative Contractor (MAC)?
Answer[/restrict paid=true]
In my opinion, yes, you would be required to submit the claim to your MAC since physical therapy, occupational therapy and speech-language pathology services are now considered covered telehealth services.[/mepr-show]
Question Updated on May 6, 2020
Can a physical therapist assistant (PTA) or occupational therapy assistant (OTA) deliver therapy services via telehealth?
Answer
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Question
If submitting claims on a 1500-claim form, what place of service (POS) code do I use on the claim form?
Answer
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Question
What modifier or modifiers must be appended to each CPT code on the claim form when delivered via telehealth?
Answer
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Question Updated May 6, 2020
Does this expansion of telehealth services include providers that submit claims on a UB-04 claim form?
Answer
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Question
Did CMS add any additional CPT codes used by physical therapists or occupational therapists as covered telehealth services?
Answer
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Question
Did CMS add any additional CPT codes used by speech-language pathologists as covered telehealth services?
Answer
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Question
Will the reimbursement for CPT codes billed via telehealth be paid at the same rate as they would for an in-person clinic visit?
Answer
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Question
Will a telehealth visit count as a visit towards a Progress Report being required every 10th visit?
Answer
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Question
Can I perform a therapy evaluation using telehealth?
Answer
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Question
If I have not seen a Medicare patient since March 2020, have not discharged them yet from therapy services, but now will begin to see them again via telehealth, must I do a new therapy evaluation or reevaluation?
Answer
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As additional information is either received or clarified from CMS, I will update this article with revised or new questions and answers. If you have a question regarding Medicare and therapy services provided via telehealth, 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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Rick do you know anything about swallowing codes treatment 92526 and eval 92610 as to why they would not have been added to the approved list?
I do not know why they were not originally included or added in this update. I would encourage you to contact ASHA as I am sure they asked for them to be included.
Does this temporary waiver apply to therapists in all settings including hospital based outpatient? I’m getting emails from National that state only therapists in private practice have been included.
Please read this article and this question:
Does this expansion of telehealth services include providers that submit claims on a UB-04 claim form?
Thank for the update, Rick. Does the language below not open the door for billing for PT/OT/Speech services furnished by hospital-based therapists provided to Medicare patients registered as hospital outpatients via a UB-04?
• For the duration of the COVID-19 emergency, CMS is waiving limitations on the types of clinical practitioners that can furnish Medicare telehealth services. Prior to this change, only doctors, nurse practitioners, physician assistants, and certain others could deliver telehealth services. Now, other practitioners are able to provide telehealth services, including physical therapists, occupational therapists, and speech language pathologists.
• Hospitals may bill for services furnished remotely by hospital-based practitioners to Medicare patients registered as hospital outpatients, including when the patient is at home when the home is serving as a temporary provider based department of the hospital. Examples of such services include counseling and educational service as well as therapy services. This change expands the types of healthcare providers that can provide using telehealth technology.
This includes provider-based departments who submit claims on a 1500-claim form with place of service code 22. The therapy services they are referring to in the Hospital Fact sheet are behavioral health therapy services. We are seeking concrete clarification from CMS and hope to have that information sometime next week.
Hi Rick: I read on the CMS sheet that some providers can bill for telehealth using audio only? Is that true for PT’s as well? We have lots of older folks who are not too tech savy!
The only CPT code allowed to be audio only for PT and OT for telehealth is 97535.
Hi Rick,
In the document from CMS dated 4-29-19: Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19
It states on the top of page 3:
Therapy Services, Physical and Occupational Therapy, All levels (CPT codes 9716197168; CPT codes 97110, 97112, 97116, 97535, 97750, 97755, 97760, 97761, 9252192524, 92507)
Can you please share what “all levels” means/references?
We are seeking clarification from CMS on what they mean by “all levels”
Can you please provide a reference/s for the questions/answer about a UB-04 claim form. Trying to find the actual documentation that notes what you stated re: CMS always paying for telehealth on 1500 claim form and never for UB-04.
Thanks
If you look at CMS and telehealth services that were covered prior to the Public Health Emergency due to COVID-19 pandemic, only certain practitioners could bill and be paid for telehealth services. They are as follows:
A physician as described in §410.20
A physician assistant as described §410.74
A nurse practitioner as described in §410.75
A clinical nurse specialist as described in §410.76
A nurse-midwife as described in §410.77
A clinical psychologist as described in §410.71
A clinical social worker as described in §410.73
A registered dietitian or nutrition professional as described in §410.134
A certified registered nurse anesthetist as described in §410.69
All of these practitioners bill for their professional services on a 1500-claim form.
Fantastic. thanks for the good news
In their press release, CMS stated, “Hospitals may bill for services furnished remotely by hospital-based practitioners to Medicare patients registered as hospital outpatients…” To me that implies that facilities billing outpatient therapy services on a UB-04 would be able to bill for telehealth. Am I interpreting that incorrectly? Thanks!
This includes provider-based departments who submit claims on a 1500-claim form with place of service code 22. The therapy services they are referring to in the Hospital Fact sheet are behavioral health therapy services. We are seeking concrete clarification from CMS and hope to have that information sometime next week.
Will the reimbursement be the same as if we saw the person in person?
Yes
Rick how about hospital based out patient physical therapy is also covered by telehealth?
Please read the article for providers who submit claims on a UB-04 claim form.
The press release did include statements allowing outpatient hospitals.
Hospitals may bill for services furnished remotely by hospital-based practitioners to Medicare patients registered as hospital outpatients, including when the patient is at home when the home is serving as a temporary provider based department of the hospital. Examples of such services include counseling and educational service as well as therapy services. This change expands the types of healthcare providers that can provide using telehealth technology.
• Hospitals may bill as the originating site for telehealth services furnished by hospital-based practitioners to Medicare patients registered as hospital outpatients, including when the patient is located at home
https://www.cms.gov/newsroom/press-releases/trump-administration-issues-second-round-sweeping-changes-support-us-healthcare-system-during-covid
This includes provider-based departments who submit claims on a 1500-claim form with place of service code 22. The therapy services they are referring to in the Hospital Fact sheet are behavioral health therapy services.
What happened to the G2061, G2062 and G2063 codes?
Those are codes to use for E-Visits and E-Visits and Telehealth services are not the same.
GREAT NEWS! But as a provider at a CAH who bills on UB 40, and is the only provider in our area of SLP, and OT services, in addition to out PT, this is such a let down. I will push for all sites to be included. Rural areas struggle as it is getting to some of our patients or having them come in. Oh well, step in the right direction!
Can teleheatlh services be provided within a SNF?
We are seeking clarification from CMS but it appears outpatient therapy can only be provided via telehealth in a private practice setting. Hope to have clarification no later than next week.
Can we now see a medicare patient via telehealth more than once per week and bill medicare
Yes
Will other payors (like Cigna, Aetna, UHC, etc) also pay for these telehealth visits in the same manner and the equivalent rate as being to seen in office ?
I would suggest you read the following 3 articles:
https://gawendaseminars.com/unitedhealthcare-and-telehealth-questions-and-answers/
https://gawendaseminars.com/cigna-and-telehealth-questions-and-answers/
https://gawendaseminars.com/aetna-and-telehealth-questions-and-answers/
Based on your information, hospital based outpatient therapies still cannot receive payment for telehealth services provided to medicare beneficiaries. Is that correct
Please read this article and this question:
Does this expansion of telehealth services include providers that submit claims on a UB-04 claim form?
Good Morning. This is great news but once again I am left a little confused as to why hospitals/institutions were not included yet when I read the CMS.gov report this was included. Can you please explain what this means then? Thank you
“Hospitals may bill for services furnished remotely by hospital-based practitioners to Medicare patients registered as hospital outpatients, including when the patient is at home when the home is serving as a temporary provider based department of the hospital.”
This includes provider-based departments who submit claims on a 1500-claim form with place of service code 22. The therapy services they are referring to in the Hospital Fact sheet are behavioral health therapy services. We are seeking concrete clarification from CMS and hope to have that information sometime next week.
Would we add the CR modifier in addition to the 95 modifier?
No
If we had already submitted previous medicare visits as e-visits, should we go back and revise them to telehealth visits since they are retroactive to March 1?
No, since an E-Visit is not the same as a telehealth visit.
hi Rick! As a hospital-based provider this news makes me a bit more frustrated, but I will keep holding out hope for a change that allows UB billing. Sigh. Thanks for all that you continue to do to keep us informed!
So no additional modifiers are required but the GP if the visit it a telehealth physical therapy visit?
In the article, please read the answer to this question:
What modifier or modifiers must be appended to each CPT code on the claim form when delivered via telehealth?
Thanks Rick, it seems like Hospitals using UB04 are still not able to bill for tele?
In my opinion, yes.
Since telehealth by PTs is now a covered service in the private practice setting, would you recommend use of an ABN if a patient chooses to self pay in an institutional setting ( billing on a UB-04 claim form)?
My opinion only is to wait for concrete clarification from CMS.
Rick, what is the rationale behind excluding providers that bill on a UB-04 claim form? It certainly doesn’t appear to be a clinical one and is obviously problematic for Rehab Agencies wanting and needing to provide telehealth services to their patients requesting it.
If you look at CMS and telehealth services that were covered prior to the Public Health Emergency due to COVID-19 pandemic, only certain practitioners could bill and be paid for telehealth services. They are as follows:
A physician as described in §410.20
A physician assistant as described §410.74
A nurse practitioner as described in §410.75
A clinical nurse specialist as described in §410.76
A nurse-midwife as described in §410.77
A clinical psychologist as described in §410.71
A clinical social worker as described in §410.73
A registered dietitian or nutrition professional as described in §410.134
A certified registered nurse anesthetist as described in §410.69
All of these practitioners bill for their professional services on a 1500-claim form.
Hi Rick,
I was reading on CMS.gov News room Press Release April 30,2020 Hospitals, Policy, Telehealth on page 5/12 the third bullet point says.
“CMS is allowing physical and occupational therapists to delegate
maintenance therapy services to physical and occupational therapy
assistants in outpatient settings. This frees up physical and
occupational therapists to perform other important services and
improve beneficiary access”
So does this mean that our PTAs can treat patients via telehealth?
No. Under outpatient therapy, PTAs and OTAs could not provide maintenance therapy. During the PHE due to COVID-19 pandemic, CMS is temporarily allowing PTAs and OTAs to provide maintenance therapy. We are seeking clarification from CMS regarding PTAs and OTAs doing telehealth visits.
Hi Rick,
Have you seen anything about documentation requirements for Telehealth outside of
– Informed consent to Telehealth
– Legal Consent/Supervision of Minor during telehealth session
– Location of provider/patient (state)
– Mode of interaction (synchronous audio/video)
– Telehealth listed in Plan?
It seems like APTA is just referring to standard defensible documentation resources but any guidance you have would be appreciated.
CMS does not require any additional documentation. You would need to check with your state practice act and other state administrative rules to see if they have any documentation requirements when services are provided via telehealth.
When you find out more information regarding UB Billing for Telehealth, will you notify us as soon as possible. Why do you think they did not include UB billing providers, like rehab agencies. We are still same provider type, providing the same level of care. I hope there is a reason other than they just forgot about us.
Thanks for your updates,
Sarah
Any updates will be posted to my website.
Hi Rick!
Coming to you from a Private Practice in upstate New York.
Regarding Medicare now covering telehealth:
(1) Are Medicare patients required to still have a physician referral to PT?
(2) Has there been any change in the requirement for the plan of care to be signed off by a physician for Medicare patients?
Thanks for all these updates so promptly! Gold membership is well worth the $!
Samantha
All the rules and regulations would still apply.
Hi Rick,
Does the threshold for Medicare still apply for outpatient services or is that waived during the pandemic? Thank you! Amy
The threshold still applies.
I contacted our MAC and asked if institutional providers, who bill using UB-04s, can provide and get paid for telehealth services. After some investigating, they stated that PT, OT and ST telehealth services can be billed on a UB-04. They stated that the information is not located on their MAC website, but was found on their internal information system.
Would you accept this authorization?
No, I would not.
Rick-does this mean that Medicare will reimburse occupational and physical therapy telehealth if billing incident to?
thank you
Yes
Rick
Thank you for the update. I thought i read that when billing e phone only call with a Medicare pt we should use E/M codes. Could you please clarify the use of the CPT code 99441-99443 for telephone only call with Medicare patients. Should we be using these codes or should we use the 98966-98968 telephone calls.
Thank you
Therapists would use CPT codes 98966, 98967 and 98968.
Hi Rick, it looks like Medicare is allowing some CPT codes to be performed by telephone only (example 92507). If a speech therapist uses telephone only for a patient, what is an example where the speech therapist would choose 92507, and an example where the therapist would choose 98966-98988? Thank you
The SLP would need to determine if they are doing a telehealth visit in lieu of an in-person visit or just checking up on the patient via a phone call and answering a question or 2. You may also want to contact ASHA and see if they have developed any examples or scenarios.
RICK ,CAN PART A OUT PATIENT REHAB FACILITIES BILL FOR TELEHEALTH?
In this article, please read the answer to this question:
Question Updated May 6, 2020
Does this expansion of telehealth services include providers that submit claims on a UB-04 claim form?
So, as a rehab agency, we are not able to bill telehealth services to Medicare. So, do you suggest we do an ABN and bill the patient or is this not allowed since telehealth is now a covered service just not a covered service by a rehab agency billing on a UB-04?
That is a decision for your organization to make. I do not provide suggestions on what to do in this forum.
For e-visits, check-in visits and telephone services, what modifiers (if any) are required when billing for these types of “non-telehealth” options?
I have article on my website under Current News that will answer your questions.
Is Medicare still covering telehealth for outpatient physical therapy as of 8/26/21?
Yes