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  • APTA Advisory: CMS Opens the Possibility of Providing Care to a Patient in the Same Building — But Not in the Same Room

    Details are in short supply, but in a recent communication with APTA, CMS seems to say that a PT's evaluation or treatment visit via real-time video, if delivered to a patient in a different room of the same building, could be billed as in-person services.

    During a national stakeholder call on April 8, CMS opened up the possibility that it would allow a clinician to provide services remotely to a patient in the same building, but not in the same room, and bill the encounter as an in-person visit. A follow-up question submitted by APTA via email seems to indicate that CMS thinks the allowance applies to PTs.

    APTA provided two examples for CMS' consideration: a PT performing an evaluation via Facetime or Skype in the same building but a different room, and a PT performing a treatment visit via Facetime or Skype in the same building but a different room.

    APTA asked if the evaluation and treatment would be considered to have been done in person and thus be billable to Medicare; and whether, if the same approach is taken in a skilled nursing facility, the minutes could be coded on the minimum data set.

    CMS' response:

    "Both of these instances you mention, where a PT performs an evaluation or treatment visit via Facetime or Skype when in the same building but in different locations describe services that can be billed as in-person services."

    “While this policy has enormous potential to help ensure continued access to therapists and other health care providers when attempting to limit contact between patients and their health care providers to prevent the spread of the COVID-19 virus, this is the only information we have on this development at the moment," said Kara Gainer, APTA director of regulatory affairs. "We don't know how this might be applied across the many health care settings, including home health. And the CMS response didn't clearly answer our question about coding these minutes in the skilled nursing facility setting."

    This is important: The allowance from CMS is not a recognition of PTs as eligible telehealth providers under Medicare. Medicare still doesn’t include PTs among the providers who can provide face-to-face telehealth; and APTA continues to urge CMS to use its authority to issue a blanket waiver to include PTs among the types of providers eligible to furnish telehealth services during the COVID-19 public health emergency.

    APTA staff will continue to pursue this information from CMS and provide more information as it becomes available.

    Update, April 10, 2020: CMS' position on how to bill services delivered in the same facility but different rooms was recently reiterated in this CMS FAQ resource (see question 9 under the "Medicare Telehealth" header).

    Visit APTA's telehealth webpage for regularly updated information and resources.


    • That’s NOT helpful. In any state where limiting trips outside of the house has been mandated, all this does is drag the patient out of the house, into a medical office building, and put them at risk. What kind of rationale is this? I’m still a staunch supporter of the APTA, but this change is a huge miss. We need full Telehealth rights just as any MD, PA, and NP with respect to our profession and ability.

      Posted by Richard Romeis on 4/9/2020 7:09 PM

    • Readers, a little more background: The CMS response described in this article had to do with a discussion about facilities that are attempting to limit contact between patients and multiple staff members. These facilities are separating their therapy teams (if the teams are big enough), with one team treating on the isolation unit while another team treats in the rest of the facility. Often, those facilities have one PT or OT and multiple PTAs and OTAs; in other words, facilities do not have enough PTs and OTs to have a PT and OT on each team, but they do have enough OTAs and PTAs to separate them into two teams. The question raised on the CMS open door forum was specifically regarding how a PT or OT can complete a supervisory visit requirement for Part B (10th visit requirement) as well as provide treatments and/or evaluations while directing the PTA or OTA. The answer from CMS was that this is possible, but would be billed as if it were furnished in-person—not a telehealth visit.

      Posted by APTA staff on 4/10/2020 8:28 AM

    • For PT's treating in home health: this would seem to improve our situation significantly. Many assisted living facilities are limiting PT/OT/ST access as "non-essential" medical providers. However, the relationships we've built may allow us into an office area, which would create better communication opportunities AND allow us to bill a full rate! I can also see the potential for PTs to see patients in the home but in different rooms, depending on home environment. Can anyone see a problem with this approach??

      Posted by Travis Hand on 4/10/2020 12:20 PM

    • Can you tell me if Noridian Medicare, Blue Cross and Blue Shield in California cover any form of telehealth? Zoom, skype, facetime? Sheila Richards Ho Rehab. Center, Inc

      Posted by Sheila Richards on 4/10/2020 12:25 PM

    • Stupid

      Posted by Hobson Theresa on 4/11/2020 9:06 AM

    • @Sheila: Please visit https://www.apta.org/telehealth/ and scroll down to “Check on the status of state emergency mandates and payers allowing telehealth.” Please note that although HHS Office for Civil Rights is currently exercising enforcement discretion of HIPAA requirements during this public health emergency, California has several state laws governing health information privacy.

      Posted by APTA staff on 4/13/2020 8:38 AM

    • From a PT patient’s perspective, one who is being treated for a workers comp injury, and who is deemed highly susceptible to COVID19 due to age and pre-existing chronic pulmonary issues, I need access to the extensive equipment provided at a PT facility. A tele/Skype or other alternative from my home with a therapist elsewhere provides NO benefit, and is a waste of the limited number of therapy sessions I am allotted under W/C. The PT offices I am required to use are set up in one large room with at 10-12 or more persons in the room all being treated at the same time. Social distancing and the enclosed space are impossible to achieve successfully as they book cases back-to-back with NO way to sterilize equipment or its facility in between patients. It’s a recipe for disaster. No thank you! I will wait until it is safe to no longer social distance.

      Posted by Amy Wad on 4/13/2020 5:02 PM

    • Is the FAQ sheet the correct reference? Is this supposed to be page 22?

      Posted by Heather Meloy -> >MPbDI on 4/14/2020 4:47 PM

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