Medicare Telehealth Questions and Answers

May 18, 2020
 / 
Rick Gawenda
 / 

This article was updated on July 23, 2020 due to Secretary Azar extending the Public Health Emergency due to the COVID-19 pandemic.

This article was updated on June 23, 2020 due to CMS clarifying if a practitioner can be out of the country and provide a telehealth visit to a Medicare beneficiary in a state where the practitioner is licensed in. See below for the question and the answer.

This article was updated on May 27, 2020 due to the Centers for Medicare and Medicaid Services expanding telehealth coverage for outpatient therapy services to include institutional providers. Please see questions and answers below for updated answers concerning outpatient therapy services delivered via telehealth by institutional providers.

With the Centers for Medicare and Medicaid Services (CMS) adding physical therapists, occupational therapists and speech-language pathologists as temporary providers of telehealth services, I have been receiving many questions regarding the provision and billing of outpatient therapy services delivered via telehealth. Below, please find the questions and answers to some of the most common questions I receive. If you do not see the question and answer you are looking for, please send me an email with your question and if appropriate and applicable to this article, I will add it.

Question (Updated October 12, 2020)
What is the expiration date of the Public Health Emergency (PHE) due to the COVID-19 pandemic that allows outpatient therapy services to be delivered via telehealth?

Answer

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Question (Added June 23, 2020)
Can the practitioner (PT, OT, SLP) be out of the country, provide a telehealth visit to a Medicare beneficiary in a state that the practitioner is licensed in and bill this telehealth visit to their Medicare Administrative Contractor?

Answer

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Question (Added June 23, 2020)
If the therapist is in one state and is enrolled with the Medicare Administrative Contractor (MAC) for that state and the Medicare beneficiary who is having the telehealth visit resides in a different state with a different MAC, to which MAC does the therapist submit the claim to?

Answer

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Question
In what settings will the Medicare program pay for outpatient therapy delivered via telehealth?

Answer (Updated May 27, 2020)

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Question
Are hospital-based therapy departments able to provide and be paid for outpatient therapy services delivered via telehealth by the Medicare program?

Answer (Updated May 27, 2020)

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Question
If I did an outpatient therapy visit via telehealth with a Medicare Part B beneficiary prior to April 30, 2020 for private practice or prior to May 27, 2020 for institutional providers and had them pay me cash, must I now refund the Medicare beneficiary and submit the claim to my Medicare Administrative Contractor (MAC)?

Answer (Updated May 27, 2020)

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Question
If I have a mobile therapy practice where I see Medicare beneficiaries in their home for outpatient therapy services, am I able to provide telehealth services under the Medicare program?

Answer

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Question
We are an outpatient therapy company and have clinics established inside of assisted living facilities. What setting is that considered?

Answer

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Question
Is a Medicare certified outpatient rehabilitation facility (rehabilitation agency) considered a private practice?

Answer

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Question
Does the Medicare program pay the same rate for outpatient therapy services as they do for an in-person outpatient therapy visit?

Answer

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Question
Does the payment amount for an outpatient therapy visit delivered via telehealth count towards the annual therapy threshold dollar amount?

Answer

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Question
Does the multiple procedure payment reduction policy apply to outpatient therapy services delivered via telehealth?

Answer

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Question
Does the Medicare program pay for an evaluation performed via telehealth?

Answer

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Question
What CPT codes does the Medicare program pay for when providing a telehealth visit?

Answer

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Question
When billing the Medicare program, can you only bill 1 CPT code per visit?

Answer

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Question
Does the Medicare program pay for a swallow evaluation (CPT code 92610) and treatment of swallowing dysfunction (CPT code 92526) if delivered via telehealth?

Answer

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Question
Does the Medicare program pay for CPT codes 97129 and 97130 (Therapeutic interventions that focus on cognitive function)?

Answer

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Question
What are the documentation requirements when seeing a Medicare beneficiary for outpatient therapy services delivered via telehealth?

Answer

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Question
Is there a limit to the number of telehealth visits I can provide to a Medicare beneficiary, either weekly or during the episode of care?

Answer

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Question
Can a Medicare patient have a combination of in-person visits and telehealth visits during an episode of care?

Answer

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Question
For Medicare Part B telehealth services, what place of service code do I use on the 1500-claim form?

Answer (Updated May 27, 2020)

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Question
When submitting claims to my Medicare Administrative Contractor for outpatient therapy services delivered via telehealth, what modifier(s) are required to be appended to each CPT code on the claim form?

Answer

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Question
Must the modifiers be appended to each CPT code in a particular order?

Answer

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Question
Must I be licensed in the state where the patient is located during the telehealth visit?

Answer

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Question
If a Medicare beneficiary usually resides in the state where I practice and I am licensed in, but for a temporary basis, has gone to live with family in another state where I am not licensed, can I do a telehealth visit with that Medicare beneficiary and submit the claim to my Medicare Administrative Contractor?

Answer

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Question
If a Medicare beneficiary does not have a computer, laptop or android phone capable of audio/visual communication, can a I call the Medicare beneficiary on their land-line phone and bill it as a telehealth visit?

Answer

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Question
Can you explain the difference between a telehealth visit and an E-Visit?

Answer

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I hope you found this article helpful. If you have a question regarding Medicare and telehealth that did not appear in this article, please email it to me at info@gawendaseminars.com and perhaps I’ll add it to this article. Thank you for being a Gold Member!


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  1. Can you provide a citation for the May 14, 2020 CMS guideline regarding non payment for telehealth for those who practice under a rehab agency or CORF?

    1. if you go back and read the FAQs, I have linked the audio from the May 14, 2020 CMS Office Hours call.

  2. The posting published by NASL states the outpatient therapy services can be provided via telehealth in SNFs, in some circumstances. Can you provide any clarity of what those circumstances may be?

    1. That language is from CMS. Most of the therapy provided in a SNF is billed under Part A and in some circumstances, SNF’s provide Part B therapy services.

  3. For those of us in out-patient hospital settings, can you provide guidance for if we should submit claims as remote services furnished via telecommunications technology or as telehealth visits? It appears that they have given us two ways of billing, with separate codes for each one. We had initiated remote services per the previous guidance, but don’t know if we should now switch due to the new approval of telehealth in our setting.

  4. hi Rick and thanks for this info! I’m wondering if you have any information on telehealth coverage for Audiology services under Medicare? I haven’t yet found specific information for their services.

    1. CMS did not expand telehealth services to audiologists. I would also recommend you contact ASHA if you have specific questions regarding audiologists providing telehealth or other telecommunication services to non-Medicare beneficiaries.

  5. Hi Rick,
    It looks like we don’t need the CR and DR (codes and modifiers) and just the 95 for tele health on a UB04 for Medicare part B patients in a hospital setting? Of course we will still need to add GP and 59 as needed.
    Could you please guide?

    1. You can read the answer to this question from this article.

      Question
      When submitting claims to my Medicare Administrative Contractor for outpatient therapy services delivered via telehealth, what modifier(s) are required to be appended to each CPT code on the claim form?

  6. Hi RIck
    I think I am missing something and hope you can direct me.. I am looking to see if there is clarification from CMS the use of 95 vs GT modifier with telehealth visits for institutional OP services. I understand from your article we are to use 95 and do not need CR or DR but was hoping to see this in writing from CMS. When I click on your “HERE” link and you reference page 70-71 I am not seeing much related to OP as a hospital to clarify this and not sure if we fall under the ASC as enrolling as hospital. I am working with our patient accounts department and seeking info from CMS. Thank you again!!!

    1. Per the article, you are to use Modifier 95 and CR modifier and DR Condition code are not required for telehealth services.

  7. Could provide any clarification on billing the facility fee for telehealth services? Can the hospital bill G0463 when the hospital provider-based department performs the clinic visit virtually for a patient at home? Or would they be able to bill Q3014 if the patient home has been made PBD by registering the patient home address or accepting the PFS rate with adding the modifier PN?

  8. I’m still confused. Are these codes (G2061, G2062 or G2063) for telehealth or e visit? Should we be using the G CPT codes with telehealth?

    1. Let me clarify my question please. We were thinking telehealth services are billed by CPT code as they would be for an in-person visit just clarified in the documentation that services were provided via telehealth due to PHE. Those G2061 – G2063 seem to be timed codes of some kind. Are they only for E visits? Or would we use them in place of other CPT codes when providing telehealth?