Think Medicare Pays for Telehealth for Therapy? Think Again!

April 17, 2020
Rick Gawenda

Today, I am receiving emails and phone calls from providers around the country that believe the Medicare program covers telehealth services provided by a physical therapist, occupational therapist or a speech-language pathologist. I have even received emails from several providers stating they provided telehealth visits to Medicare beneficiaries, submitted the claim to their Medicare Administrative Contractor using place of service code 02 on the 1500-claim form and appended modifier 95 or modifier 95 and the GP modifier to the CPT code(s) on the claim form and were paid.

I hate to tell you, but you were paid in error. As of April 17, 2020 at 3:30pm EDT, the Centers for Medicare and Medicaid Services (CMS) has still not added physical therapists, occupational therapists and speech-language pathologists as telehealth providers. Click HERE and begin listening at 6 minutes and 44 seconds. This is from a CMS call on April 14, 2020.

In addition, read the April 7, 2020 Q&A in this document on page 18 of 21. Here is the answer to the question: “So, the current status for therapy services in general is that the therapy services are available on the telehealth
list. But, at present, the physical therapists, occupational therapists, and speech language pathologists are not eligible to bill for telehealth services. We are currently examining potential flexibilities based on very recent changes legislatively that would allow us to consider making those changes.”

Here is another reference from the April 8, 2020 CMS call on Telehealth Services. Begin reading on page 9.

What CMS did do on March 30, 2020 is add many of the CPT codes that are normally billed by physical therapists, occupational therapists and speech-language pathologists as covered telehealth services, but DID NOT add physical therapists, occupational therapists or speech-language pathologists as telehealth providers. Read page 19239 bottom paragraph 2nd column and top of 3rd column of the interim final rule. This is what CMS said:

“In light of the PHE for the COVID–19 pandemic, we believe that the risks associated with confusion are outweighed by the potential benefits for circumstances when these services might be furnished via telehealth by eligible distant site practitioners. We believe this is sufficient clinical evidence to support the addition of therapy services to the Medicare telehealth list on a category 2 basis. However, we note that the statutory definition of distant site practitioners under section 1834(m) of the Act does not include physical therapists, occupational therapists, or speech- language pathologists, meaning that it does not provide for payment for these services as Medicare telehealth services when furnished by physical therapists, occupational therapists, or speech- language pathologists.”

So please, stop the spread of incorrect news!!!!!! When CMS does expand telehealth to include physical therapists, occupational therapists, or speech- language pathologists, that information will be shared by your respective professional organizations (APTA, AOTA, ASHA) as well as myself.

If you want to do telehealth visits on your Medicare patients, hold the claims for now and wait and see what CMS does regarding expanding telehealth to physical therapists, occupational therapists, or speech- language pathologists and making it retro-active to a certain date inMarch 2020 perhaps.

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This article is not intended to and does not serve as legal advice or as consultative services, but is for general information purposes only.

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  1. Thank you for all your hard work on this issue. It’s is SO important. I totally agree and support exactly what you are saying. With that said, I called our Medicare Noridian hotline on the day that the inerim rule was given and was told by the representative that as a physical therapist, private practice owner, I could bill under the conditions , 02, modifiers, etc, etc… she gave us clear instructions how to bill “telehealth” as a physical therapist with all the codes… exactly as you outlined for the scenario that got paid but is technically “in error”. All this to say that, I agree with your prediction that Medicare will eventually pay for “telehealth” especially if they are directly telling clinics like mine, clearly over the phone that they will pay for “telehealth”services and subsequently actually paying. We appreciate all your hard work on this. Just wanted to give some insight from the “trenches”

  2. So thankful for your expertise in translating the language of Medicare to English for us! One of the biggest hurdles right now is helping patients with Medicare Advantage plans understand their benefits. Usually they think that either, 1) they are the same as traditional Medicare or 2) they don’t understand that because we are out-of-network for all but (Medicare/Tricare/BCBS/BlueMedicare) that the waiver for patient cost-share doesn’t apply. Lots of phone calls and explaining for that issue.

  3. Hi Rick!

    Any update to this in the last 10 days? Seems like this “fake news” is still circulating.. I am a medical biller for PT/OT and my clients are questioning my advise that Medicare is not covering telehealth…

    1. No change yet. Website will be updated once CMS adds PTs, OTs and SLPs as eligible telehealth providers.

  4. Any clarity on if an e-visit counts toward the 10th visit progress report for Medicare? I see that deductibles do apply, but the APTA states an e-visit is not considered a treatment, so I doesn’t count as a visit. I need CMS rules on this one before I’ll advise not to count toward visits.

    1. An E-Visit is not considered a treatment day, hence, would not count as a visit towards the 10th visit Progress Report. There is nothing written specifically by CMS on this question.