CMS Updates Telehealth and Outpatient Therapy Services

April 1, 2020
 / 
Rick Gawenda
 / 

On March 30, 2020, the Centers for Medicare and Medicaid Services (CMS) issued an interim final rule with comment period titled “Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency“. This interim final rule with comment period contains important information for not only outpatient physical, occupational and speech-language pathology therapy services, but also therapy provided under a Home Health Agency plan of care and inpatient rehabilitation facilities.

Lets start with outpatient physical, occupational and speech therapy services and find out what’s new!

Question
Did CMS add physical therapists (PTs), occupational therapists (OTs) and speech-language pathologists (SLPs) as distant site practitioners under section 1834(m) of the Act ?

Answer

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Question
What CPT codes commonly used by PTs, OTs and SLPs did CMS add to the list of covered Medicare telehealth services?

Answer

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Question
What qualified professionals can bill the CPT codes that CMS has added temporarily to the covered Medicare telehealth services?

Answer

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Question
Did CMS clarify what settings can bill for E-Visits?

Answer

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Question
Can institutional settings (i.e. rehab agencies, home health agencies, and hospitals) bill and be paid for the HCPCS Level II codes G2061, G2062, and G2063?Answer

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Question
Did the Centers for Medicare and Medicaid Services clarify whether a physical therapist assistant (PTA) or occupational therapy assistant (OTA) can perform or provide an E-Visit?

Answer

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Question
Did CMS clarify if they were making HCPCS Level II codes G2061, G2062 and G2063 either “always therapy” or “sometimes therapy” services?

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Question
What are HCPCS Level II codes G2010 and G2012?

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Question
Can PTs, OTs and SLPs be paid for HCPCS Level II codes G2010 and G2012 and if yes, in what settings?

Answer

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Question
What modifier(s) must be appended to G2010 and G2012 on the claim form?

Answer

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Question
Will CMS pay physical therapists, occupational therapists and speech-language pathologists for telephone assessment and management service (CPT codes 98966, 98967 and 98968) and if yes, in what settings?

Answer

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Question
Do CPT codes designated as “sometimes therapy” services count towards the annual therapy dollar threshold?

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Question
How can I access the resource to support the answers you have provided?

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Question
What did CMS state about “home-bound” status for Medicare beneficiaries to receive home health services?

Answer

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Questions
Does this interim final rule have any updates on Inpatient Rehabilitation Facilities?

Answer

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I hope you found this article helpful. This article will be updated with additional questions and answers so be sure to check back. Thank you for being a Gold Member!



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  1. Thank you so much for your work! In light of this new information, will therapists need to wait 7 days after furnishing their last “E-visit” before charging for a telehealth visit?

    1. As of March 31, 2020 at 6:40pm PDT, CMS has not added physical therapists, occupational therapists and speech-language pathologists as distant site practitioners for telehealth services.

  2. What am I missing? In your first answer, you state “…This means that PTs, OTs and SLPs still can’t provide telehealth services to their Medicare beneficiaries and have those services paid for by the Medicare program.” The 2nd answer “…CMS has added the following CPT codes to covered Medicare telehealth services as a temporary condition…and includes codes such as 97110…” How is it that PT’s cannot provide telehealth services yet some of our codes have been added as covered services.

    Thanks!

    1. You are missing the fact that physicians and some non-physician practitioners can provide therapy services under Medicare Part B. Per CMS: QUALIFIED PROFESSIONAL means a physical therapist, occupational therapist, speech-language pathologist, physician, nurse practitioner, clinical nurse specialist, or physician’s assistant, who is licensed or certified by the state to furnish therapy services, and who also may appropriately furnish therapy services under Medicare policies. Qualified professional may also include a physical therapist assistant (PTA) or an occupational therapy assistant (OTA) when furnishing services under the supervision of a qualified therapist, who is working within the state scope of practice in the state in which the services are furnished. Assistants are limited in the services they may furnish (see section 230.1 and 230.2) and may not supervise other therapy caregivers.

      1. Thank you for clarifying. It’s disappointing that we aren’t listed as providers of telehealth. I guess this means I will write yet another letter to Seema Verma.

      2. So, we can provide telehealth services in either a hospital based or private practice if we use the CPTs that are “temporary additions” because of the COVID outbreak?

        1. As of April 7, 2020 at 12:35pm EDT, CMS ha snot added physical therapists, occupational therapists and speech-language pathologists as providers of telehealth services.

  3. I am so confused! So specific therapy codes are now covered under this temporary situation, but Medicare is not allowing/paying PTs, OTs and SLPs to bill telehealth and be remibursed for the service??

    1. You are correct. As of March 31, 2020 at 6:40pm PDT, CMS has not added physical therapists, occupational therapists and speech-language pathologists as distant site practitioners for telehealth services.

  4. According to page 2 of the March 30th CMS posting “Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19”, it appears that therapy services are payable which states “Licensed clinical social worker services, clinical psychologist services, physical therapy services,occupational therapist services, and speech language pathology services can be paid for as Medicare telehealth services.” See this link:

    https://www.cms.gov/files/document/covid-19-physicians-and-practitioners.pdf?utm_source=podia&utm_medium=broadcast&utm_campaign=165504

    1. As of today, April 16, 2020 at 8:00am PDT, CMS has still not added PTs, OTs and SLPs as providers of telehealth services.

  5. Good Morning. I just heard that APTA notes that CMS may not cover e-visits for institutional billers as it is requiring private practice to use the GP modifier. But this is a modifier our hospital has always used so I am a little confused by this statement.
    I also do not understand how in this particular time we are separating out who and how ones gets paid based on the physical location. I understand there are different contracts and different services/regulations during “normal” circumstances but this is an unprecedented situation. We just need to get these patients seen and followed to be sure they are getting the services they need. Therapists just want to do what is right for the patient in following the proper channels and hope to get some reimbursement.
    Thank you

  6. Do you have any thoughts on why much of the movement for TeleHealth with CMS and private insurance seems to exclude institutional settings such as Hospital-based OP Therapy? Incident-to directly states non-institutional settings.

  7. Maybe I am missing it but still not clear if hospital based outpatient facilities can provide and bill for e-visits. Thank you

  8. I do not see exclusion of OP (UB) billing evisits as you stated. Can you provide the citation?

  9. While trying to define the verbiage used in this particular document issued by CMS
    Medicare Telehealth
    Clinicians can now provide more services to beneficiaries via telehealth so that clinicians can take care of
    their patients while mitigating the risk of the spread of the virus. Under the public health emergency, all
    beneficiaries across the country can receive Medicare telehealth and other communications technology based services wherever they are located. Clinicians can provide these services to new or established
    patients. In addition, providers can waive Medicare copayments for these telehealth services for
    beneficiaries in Original Medicare.

    I looked up the following 2 definitions…. and based on the CMS definition- it appears that PT is included…

    from the CMS website- Defining Clinicians:
    The term clinician refers to a healthcare professional qualified in the clinical practice of medicine. Clinicians are those who provide: principal care for a patient where there is no planned endpoint of the relationship; expertise needed for the ongoing management of a chronic disease or condition; care during a defined period and circumstance, such as hospitalization; or care as ordered by another clinician. Clinicians may be physicians, nurses, pharmacists, or other allied health professionals.

    defining allied health professionals

    Title 42 of the US Code states that allied health professionals are any health professional (other than a registered nurse or physician assistant) who has not received degrees in allopathic medicine, osteopathic medicine, dentistry, veterinary medicine, optometry, podiatric medicine, pharmacy, public health, chiropractic, health administration, clinical psychology, social work, or counseling. Moreover, this section of the US Code explains that allied health professionals have a certificate or a degree in a science relating to health care and share in the delivery of services related to disease identification, evaluation, and prevention; diet and nutrition; health promotion; rehabilitation; or health system management

    1. Not sure what you are asking. You need to read the interim final rule and it’s very clear about physical therapists, occupational therapists and speech-language pathologists.

  10. The final rule says on page 34 that we are considered category-2. Doesn’t that now allow therapist to provide therapy which the APTA is supposed to protect and stop with these grammatical games during a crisis?

      1. I wish it was clear for the average professional with a doctorate degree to understand. It reads as an opinion to an unclear determination of confusion. https://www.cms.gov/files/document/covid-19-physicians-and-practitioners.pdf describes on two unique line items both therapy services and licensed therapists as covered Telehealth under Medicare. The redundant sentence wouldn’t be necessary unless they were highlighting that licensed therapist as covered Medicare Telehealth providers now?

  11. what are your thoughts about the Incident To option for private practice? (especially since the in office suite requirement has been waived)

  12. Do we follow the 8 minute rule for telehealth for Medicare Part B patients and will reimbursement work as if the patient is in the Clinic?

    Thanks

    1. As of March 31, 2020 at 6:40pm PDT, CMS has not added physical therapists, occupational therapists and speech-language pathologists as distant site practitioners for telehealth services.

        1. That is the decision of the clinician when to discharge a Medicare beneficiary from therapy services.

  13. Would we be able to do private pay Telehealth visits for Medicare patients in out-patient private practice setting? If yes, would this require an ABN to be completed?

    Thank you

  14. Can you Clarify CPT codes 98966 – 98967 for me please regarding “not originating from a related assessment and management service with the previous 7 days etc.

    1. To expand on my question – does a physical therapy visit count as an E/M service or just the PT Evaluation?

      1. A physical therapy in-person visit counts as a PT visit. It has never counted as an E/M service.

    2. Means you did not see them in the clinic during the past 7 days for the same reason/condition you are now doing a Telephone call.

  15. Thank you for providing the source! We are so fortunate to have you interpret a great deal of this for us.

    Stay well!

  16. Rick. I understand that evisit could be done through encrypted email. We have unencrypted email . Our patients sign an agreement allowing email communication with us , accepting it as non encrypted. We were advised this is acceptable. Can we therefore use our email for evisit with this condition. Figuring perhaps more likely a yes also given some relaxation on HIPAA rules? thanks

  17. For the commonly billed CPT codes now allowed to be bill for telehealth, should we use Modifier 95 or do the want CR like the e-visit codes?

    Thank you for your hard work.

    1. As of March 31, 2020 at 6:40pm PDT, CMS has not added physical therapists, occupational therapists and speech-language pathologists as distant site practitioners for telehealth services.

  18. Tried looking up pricing with CMS for reimbursement pf codes 98966, 98967 and 98968 and got this message:

    “The current Physician Fee Schedule does not price the requested HCPCS Code(s).”

    Will CMS be adding these codes soon? I did find pricing for the G codes.

    Do you advise that we hold Medicare billing until they have updated their systems with codes, if we bill now will they deny codes 98966,98967,98968?

    Thank you for taking time to answer all our questions, as its much appreciated…

  19. Regarding e-visits, are critical access hospitals an exception given that they bill differently from a non-CAH and are rural?

  20. Thank you for clarifying and editing these Q&A as it is more clear. I look forward to your webinar tomorrow and hope to hear this changes for the benefit of all.

  21. Since CMS is still not acknowledging PTs/OTs for Telehealth, what if Medicare B is secondary to a commercial plan that does allow for Telehealth?
    For example: A PT does Telehealth on a patient who has commercial BCBS as their primary plan & when charges are entered the required POS and modifier are used per BCBS requirements, when the 2ndry claim goes to Medicare B will they just deny as non-covered services?

    thanks!

  22. What about supervision of Assistants via technology. Is that considered telehealth? I’m curious with staffing shortages if we can meet supervisory requirements within states and across states by using technology to complete the supervisory visit?

  23. CMS has stated that physical therapists can bill for telephone service for an established patient. What about a patient who is new – initial eval -can you “see” the patient on Doxyme? Would you then bill as a telephone service over the 7 day period?

    1. Telehealth and Telephone Services are not the same. Think of telehealth as a replacement for an in-person visit and the telephone service to prevent an in-person visit.