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  • CMS Guidance Allows PTs, PTAs in Private Practice to Provide Services Via Telehealth

    In a major shift strongly advocated by APTA members, CMS will now include PTs and PTAs in private practice among the providers able to bill for services provided through real-time face-to-face technology. But there are requirements.

     

     [Editor's note: This story was updated on May 15 after CMS confirmed that PTAs were also included in the guidance information.]

     

     The change is happening, albeit incrementally: New guidance issued by CMS now allows PTs and PTAs in private practice to make full use of telehealth with their patients under Medicare Part B. Previously, only limited e-visits and other “communication technology-based services” were allowed; the change now includes PTs among the health care providers permitted to bill for real-time face-to-face services using telehealth. This policy change follows a robust advocacy campaign by APTA members and staff.

    Aside from telehealth, the revised guidance and accompanying interim final rule contain other provisions relevant to PTs and PTAs. APTA will share these details in subsequent PT in Motion News articles. Also, there are multiple details of the telehealth and other provisions that haven't been fully explained by CMS. APTA is working to find answers that fill in the gaps.

    The Basics

    • Physical therapists in private practice are eligible to bill Medicare for certain services provided via telehealth. [Editor’s Note: APTA is seeking confirmation as to whether services furnished by PTAs via telehealth are eligible for reimbursement.]
    • Services that started as of March 1, 2020, and are provided for the duration of the public health emergency are eligible.
    • These CPT codes are eligible to be billed: 97161- 97164, 97110, 97112, 97116, 97150, 97530, 97535, 97542, 97750, 97755, 97760, and 97761.
    • Patients may be either new or established.
    • These visits are for the same services as would be provided during an in-person visit and are paid at the same rate.
    • Patients may be located in any geographic area (not just those designated as rural), and in any health care facility or in their home.

    Here are the codes you can use.
    These codes are eligible to physical therapists to furnish and bill under the Medicare Physician Fee Schedule when provided via telehealth:

    ICPT codes 97161- 97164, 97110, 97112, 97116, 97150, 97530, 97535, 97542, 97750, 97755, 97760, and 97761. See the full list of codes eligible to be furnished and billed via telehealth under Medicare.

    When billing claims for telehealth services provided on or after March 1, 2020, and for the duration of the public health emergency, bill with:

    • IPlace of Service code equal to what it would have been had you furnished the service in person;
    • IModifier 95, indicating that you did indeed perform the service via telehealth; and
    • IThe GP modifier.

    APTA is seeking clarification from CMS regarding institutional billing of telehealth services.

    You will be reimbursed as if the service was delivered in person, and you can find rates for codes being reimbursed under the Medicare Physician Fee Schedule via telehealth using the APTA MPPR Fee Schedule Calculator or CMS Physician Fee Schedule Look-Up Tool.

    You can provide services from your home.
    During this public health emergency, CMS is allowing PTs in private practice (as well as other providers) to furnish telehealth services from their homes without reporting their home address on their Medicare enrollment while continuing to bill from their currently enrolled location.

    There are technology requirements. Follow them.
    Services on the Medicare telehealth services list must be furnished using, at a minimum, audio and video equipment permitting two-way, real-time interactive communication between you and your patient.

    What if two-way audio and video technology isn't available? CMS acknowledges that there are circumstances where prolonged audio-only communication between you and the patient could be clinically appropriate yet not fully replace a face-to-face visit. In these cases, it's important to remember that during the public health emergency Medicare pays separately for audio-only telephone assessment and management services described by CPT codes 98966-98968. This APTA quick guide can help you learn more about telephone assessment and management services.

    Documentation matters. A lot.
    Keep in mind the documentation needed to have a proper compliant telehealth program. For more information, view APTA's Defensible Documentation resources. Also be sure to document the type of technology you used for the evaluation or treatment. For information about obtaining and documenting informed consent, and policies and procedures that you should have in place before furnishing telehealth, visit APTA’s implementing telehealth in your practice webpage.

    What about HIPAA?
    During this health crisis, the HHS office for Civil Rights is relaxing enforcement and waiving penalties for HIPAA violations against clinicians who in good faith use everyday applications that allow for video chats, such as Apple FaceTime and Skype. But keep in mind: HHS, the Office of the Inspector General, and the Department of Justice will monitor for health care fraud and abuse, including potential Medicare coronavirus scams.

    Another important point: You must adhere to any state laws governing privacy and security of patient data.
    For additional privacy protections while using video-based telehealth, consider providing services through technology vendors that offer HIPAA business associate agreements with their video communication products. APTA’s Health Policy and Administration hosts a list of rehabilitation telehealth vendors.

    Beneficiary cost sharing? Up to you (but waivers won't be covered by Medicare).
    Nothing in the guidance or interim rule requires you to reduce or waive copays or other cost-sharing that a Medicare beneficiary may owe for telehealth services during the health crisis, but you will not be subject to administrative sanctions if you do. This applies to face-to-face telehealth services as well as to non-face-to-face services furnished through modalities such as virtual check-ins and e-visits. However, keep in mind that Medicare will not cover the cost of any waived cost sharing.

     

    Comments

    • What is the rationale behind CMS excluding institutional providers (Rehab Agencies) from billing for e-visit/telehealth services? There is clearly no reasonable clinical explanation for this.

      Posted by gtrubell on 4/30/2020 8:22 PM

    • This document from CMS states "Hospitals may bill for services furnished remotely by hospital-based practitioners to Medicare patients registered as hospital outpatients," https://www.cms.gov/newsroom/press-releases/trump-administration-issues-second-round-sweeping-changes-support-us-healthcare-system-during-covid

      Posted by Jennifer Lyons on 5/1/2020 12:15 AM

    • Can you bill for more than one visit per week. can you have two visits per week with Medicare patients

      Posted by Cindy Scudero on 5/1/2020 8:14 AM

    • @gtrubell: We are working to gain additional clarification from CMS regarding the billing of therapy by institutional providers under Medicare Part B.

      Posted by APTA staff on 5/1/2020 10:31 AM

    • @Jennifer: We are seeking clarification from CMS regarding whether hospitals are eligible to bill for telehealth services furnished by PTs, as the language in the interim final rule and accompanying guidance is unclear. This is the list of waivers for hospitals: https://www.cms.gov/files/document/covid-hospitals.pdf . We will release additional information as soon as we have a better sense from CMS regarding whether hospitals also are eligible to bill for physical therapy services furnished via telehealth to hospital outpatients.

      Posted by APTA staff on 5/1/2020 10:32 AM

    • @Cindy: The frequency of treatment should be consistent with the clinical findings and the goals established for the patient as outlined in the plan of care.

      Posted by APTA staff on 5/1/2020 10:32 AM

    • I read the CMS press release and I did not see anywhere where it differentiated institutional vs. private practice rules? Can you explain where you are seeing this as a limitation on institutional providers?

      Posted by Frank Moreno on 5/1/2020 10:52 AM

    • would the place of service be 02?

      Posted by kim on 5/1/2020 11:38 AM

    • You state, “Also be sure to document the type of technology you used for the evaluation or treatment.” Do you have a source for this? I have not found a primary source for this requirement. I would like to find an original source and get more information about the extent to which we need to document this information (platform, browser, OS, hardware, ISP, etc.).

      Posted by David on 5/1/2020 3:59 PM

    • You state, "Also be sure to document the type of technology you used for the evaluation or treatment." Do you have a primary source on this? I have been unable to locate an original source that says this. I would like to know where it comes from and the extent to which we should document the technology (platform, browser, OS, hardware, ISP, etc.).

      Posted by David on 5/1/2020 4:40 PM

    • You state, "[b]ill with: Place of Service code equal to what it would have been had you furnished the service in person." Do you have a source for this? Why would we not bill with the telehealth place of service code ("02")?

      Posted by David on 5/1/2020 4:47 PM

    • Our profession needs to be careful where this may take us. Our value comes firstly from our hands. There are a lot of profit first sharks in the water. We need to keep the integrity of our profession in the forefront and not become overly reactionary in the short term.

      Posted by C Swisher on 5/1/2020 9:23 PM

    • It is absolutely ridiculous that CMS would retro-approve Telehealth when all the while those of us who were trying to still care for pts and follow the incredibly limiting but mandated "phone only" interactions are snubbed by deciding to backdate approval to pay providers who either "guessed right" or had "insider info" that MC would, in fact, go back and approve video based care when their mandate was that we weren't approved. So when does it become acceptable to ask for clarification, be given the mandate, and the PT's and patients who follow it are essentially penalized with inferior treatment interactions and reimbursement, but those who chose to IGNORE CMS's guidelines and withhold billing get rewarded? Wish for our patients' well being and for our businesses rightful reimbursements for work we should've been allowed to do that we would've guessed more correctly. But we should not have a system that retro approves complete disregard for the rules set out for us to follow. Why have guidelines if you're going to backdate approval for having ignored them? Crazy

      Posted by Mike Napierala on 5/2/2020 8:54 AM

    • @Frank: The CMS guidance states: Pursuant to authority granted under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) that broadens the waiver authority under section 1135 of the Social Security Act, the Secretary has authorized additional telehealth waivers. CMS is waiving the requirements of section 1834(m)(4)(E) of the Act and 42 CFR § 410.78 (b)(2) which specify the types of practitioners that may bill for their services when furnished as Medicare telehealth services from the distant site. The waiver of these requirements expands the types of health care professionals that can furnish distant site telehealth services to include all those that are eligible to bill Medicare for their professional services. This allows health care professionals who were previously ineligible to furnish and bill for Medicare telehealth services, including physical therapists, occupational therapists, speech language pathologists, and others, to receive payment for Medicare telehealth services. https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf. APTA and other stakeholders are seeking clarification from CMS regarding whether institutional providers are eligible to bill for telehealth services furnished by PTs under Medicare Part B, as the language in the interim final rule and accompanying guidance is unclear.

      Posted by APTA staff on 5/4/2020 8:37 AM

    • @Kim: When billing professional claims for all telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE), bill with: Place of Service (POS) equal to what it would have been had the service been furnished in-person. See: https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-04-03-mlnc-se

      Posted by APTA staff on 5/4/2020 8:38 AM

    • • @David: Documenting the type of telehealth technology used to conduct the visit is considered best practice and supports the billing of telehealth services.

      Posted by APTA staff on 5/4/2020 8:38 AM

    • • @David: Per CMS, When billing professional claims for all telehealth services with dates of services on or after March 1, 2020, and for the duration of the Public Health Emergency (PHE), bill with: Place of Service (POS) equal to what it would have been had the service been furnished in-person.https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-04-03-mlnc-se

      Posted by APTA staff on 5/4/2020 8:39 AM

    • There is confusion as to which telephone codes we should be using for billing PT services. Latest info says to use E/M codes 99441-43 but previous info says to use 98966-68 for phone calls. Which ones should we be using for out patient services via phone?

      Posted by Barbara Spillane on 5/4/2020 12:19 PM

    • The answer to the institutional providers does not explain where you find this guidance from CMS to be unclear. From everything that I have read, and from what you have also posted, CMS does not make any reference to private practice versus hospital-based outpatient providers. I am curious as to where you see this language as unclear, as it was never spelled out either way. Many of us are waiting on this clarification, but does there really need to be? Thank you

      Posted by Frank Moreno on 5/4/2020 12:32 PM

    • • @Barbara: Physical therapists are not eligible to use the E/M codes. For telephone assessment and management services, use CPT codes 98966-98968. The CPT codes eligible to be covered under the Medicare Physician Fee Schedule when furnished via telehealth by PTs can be found here: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes . Please note that CPT 97535 is eligible to be furnished via audio-only communications. The other services furnished by PTs via telehealth must be furnished using real time audio and visual technology.

      Posted by APTA staff on 5/5/2020 8:11 AM

    • @Frank: Please note that CMS states that it is waiving the types of practitioners “that may bill for their services when furnished as Medicare telehealth services from the distant site. The waiver of these requirements expands the types of health care professionals that can furnish distant site telehealth services to include all those that are eligible to bill Medicare for their professional services.” (See: https://www.cms.gov/files/document/covid-19-physicians-and-practitioners.pdf) This statement indicates that CMS is only adding those health care professionals who are eligible to bill for their professional services, such as PTs in private practice, who bill for their services on the CMS-1500 claim form, and would not encompass institutional settings that bill for therapy services furnished by therapists and therapist assistants via the UB-04 claim form. We will be asking CMS for clarification during CMS’ May 5 office hours call, including in relation to hospital outpatient departments and what is permitted under the hospital without walls initiative.

      Posted by APTA staff on 5/5/2020 8:12 AM

    • Clarification: The official announcement asks for the CR modifier for Medicare part B, and doesn't say anythign about any other modifiers (https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf). Do you have a source for the 95 and GP modifiers? Are we to include two separate modifiers on the same code? Thank you for working so hard to keep us up to date. I know Medicare can be difficult to understand under normal circumstances, and that the environment is changing daily. I really appreciate the work you are doing investigating these details and then getting it out; it is invaluable to the profession (and especially my clinic!).

      Posted by Lee Yek on 5/5/2020 12:56 PM

    • Any clarification regarding coverage for therapists using UB-04 form working in hospital outpatient therapy department at today's office hours call?

      Posted by Margaret Bronson -> ?MWcDN on 5/5/2020 4:49 PM

    • Do HIPAA rules allow PT clinic to give phone numbers and email addresses to clinician at home?

      Posted by Lori on 5/5/2020 7:31 PM

    • Can you clarify what we need to report with our documentation: Do I need to report the exact platform I am using? (doxy.me) If I report "telemedicine virtual visit" does that explain that the visit was audio and video or do I need to spell out that it was audio and video conferencing?

      Posted by Stephanie on 5/6/2020 8:55 AM

    • Any word if Critical Access Hospitals who bill on a UB claim are excluded from billing Telehealth for Medicare beneficiaries ? We do not always follow the regulations that apply to other institutions who bill on a UB claim.

      Posted by Ryan on 5/6/2020 1:35 PM

    • @Lee: Please see: https://www.cms.gov/files/document/2020-04-03-special-edition.pdf for guidance on 95 modifier and POS code. The GP modifier also is required because the services are being furnished under an outpatient physical therapy plan of care.

      Posted by APTA staff on 5/6/2020 3:25 PM

    • @Margaret: APTA will be publishing guidance via PT in Motion news on May 6, 2020.

      Posted by APTA staff on 5/6/2020 3:25 PM

    • Way to leave your hospital based therapists out of telehealth. How on earth did this happen? CMS can come up with 62 different modifiers and location codes to use but they can overcome the type of claim form that is submitted on? We are all licensed PTs, and should therefore recognized providers. Everyone has been asking for weeks about the UB04. No reason they couldn’t figure out the logistics. So sad and disappointing for this APTA member!

      Posted by Andrea on 5/6/2020 7:55 PM

    • The APTA “strongly advocated”????? So why are the hospital based therapists being left out?

      Posted by Andrea on 5/6/2020 7:58 PM

    • @Andrea: Please see APTA’s recently published PT in Motion news story discussing the potential flexibility for hospital-based PTs and PTAs: http://www.apta.org/PTinMotion/News/2020/5/6/CMSClarificationsHospitalANDPTAs/

      Posted by APTA staff on 5/7/2020 8:03 AM

    • I find it interesting that CMS has added 99441-99443 to the list of Medicare eligible Telehealth services, but 98966-98968 is not on the list. Was this an oversight or intentional?

      Posted by Cynthia on 5/8/2020 12:03 PM

    • Does the 10 visit progress note apply to Telehealth? Are we supposed to do a progress note every 10 visits like in person visits? Thank you

      Posted by Parul Haribhai on 5/11/2020 5:04 PM

    • @Cynthia: Effective April 30, CMS increased the allowable of 99441, 99442, and 99443 (telephone E/M). CPT codes 98966-98968 (telephone assessment and management services) are covered by Medicare when furnished by PTs, but are not paid at a rate equivalent to services furnished in-person.

      Posted by APTA staff on 5/12/2020 8:11 AM

    • @Parul: CMS has not provided any flexibility related to the completion of the 10th visit progress report, which must be written by the PT (or OT or SLP). Please continue to follow Medicare guidelines that requires the information in the progress report to be written by the therapist.

      Posted by APTA staff on 5/12/2020 8:12 AM

    • Can home health agencies provide telehealth services? Is the reimbursement rate the same? What billing codes should be used? Thank you.

      Posted by Alyssa Klein on 5/15/2020 7:47 AM

    • Any updates for those of use who bill on a UB04? Thanks

      Posted by Jennifer Klesat on 5/17/2020 6:57 AM

    • @Alyssa: For Medicare Part A, CMS does not have the statutory authority to allow HHAs to furnish and bill telehealth. For Medicare Part B, APTA is continuing to advocate that CMS recognize HHAs and other institutional settings to furnish and bill telehealth under Medicare Part B. For additional information, please see CMS’ overview of flexibilities for HHAs: https://www.cms.gov/files/document/covid-home-health-agencies.pdf We encourage individuals to submit comments to CMS on its most recent interim final rule, urging the agency to recognize institutional settings as eligible to bill for outpatient therapy furnished via telehealth using APTA’s unique template letter found on our regulatory take action webpage. See below: Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency and Delay of Certain Reporting Requirements for the Skilled Nursing Facility Quality Reporting Program: Among other changes, the CMS interim final rule expands coverage of maintenance therapy furnished by PTAs under Medicare Part B and discusses flexibility afforded to hospitals under the “Hospitals Without Walls” initiative. APTA will submit comments to CMS, and we encourage individuals to consider submitting comments using APTA's unique template letter. Review proposed rule. Deadline to submit comments: July 7, 2020.

 http://www.apta.org/RegulatoryIssues/TakeAction/

      Posted by APTA staff on 5/18/2020 8:41 AM

    • @Jennifer: Unfortunately, CMS has not yet recognized institutional settings that bill Medicare Part B as authorized telehealth providers. We and the other associations that represent these providers are meeting with CMS this week to discuss this issue.

      Posted by APTA staff on 5/18/2020 8:41 AM

    • Do you have information regarding licensure requirements for providing telehealth in a different state. Our clinic is in Idaho but is very close to the Washington state line. Our therapists, some of whom are not licensed in WA do see WA residents in our Idaho clinic. However, our assumption has been that therapists must be licensed in WA in order to see a patient via tele health while the patient is at their residence in WA. Is this assumption correct? I cannot find a good source for this information

      Posted by Justin on 5/20/2020 2:14 PM

    • @Justin: You need to be licensed or hold a compact privilege in the state where the patient is located. If you are, then you also would need to ensure that telehealth is within the PT or PTA's scope of practice in the state where the patient is located If you're not licensed in the state(s) where the patient is located, I would suggest reviewing the state licensing board's website and also the applicable APTA state chapter's website to determine whether the state has waived licensure requirements, either individually or categorically, for physical therapy practice, or if the state has any kind of flexibilities for out-of state providers to furnish in-person or telehealth services to patients in that state. For example, some states are issuing accelerated, temporary licenses. For additional information: https://www.fsbpt.org/Free-Resources/Licensing-Authorities-Contact-Information https://www.fsbpt.org/Portals/0/documents/news-events/Jurisdiction_Licensure_Exemptions_Requirements_Waivers_during_COVID-19.pdf FSBPT Summary: https://www.fsbpt.org/Portals/0/documents/news-events/Jurisdiction_Licensure_Exemptions_Requirements_Waivers_during_COVID-19.pdf See also: https://www.apta.org/Telehealth/LegislationRegulation/

      Posted by Kelly Gardner -> ?IX^<G on 5/21/2020 8:17 AM

    • Is there any update following your meeting with CMS last week to discuss recognition of institutional settings using the UB claim form for telehealth coverage?

      Posted by Jacob Bal on 5/25/2020 10:49 AM

    • @Jacob: Please stay tuned. CMS has indicated during its last several office hours calls that it will be issuing guidance on this topic in the very near future.

      Posted by APTA staff on 5/26/2020 4:02 PM

    • At the beginning of all this, MC set rules in place for billing in timed increments along with a 7 day rule and how long the patient can be treated for. Do these rules still apply? or no more as they are allowing normal codes to be billed now? Thank you for your time.

      Posted by Sandi on 5/27/2020 12:30 PM

    • @Sandi: If you’re referring to the communication technology-based services (not considered “Medicare telehealth” services), then those rules still apply. For more information about those services and the accompanying limitations, please visit: https://www.apta.org/Telehealth/COVID-19/Modalities/

      Posted by APTA staff on 5/28/2020 10:06 AM

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