COVID-19 is changing the landscape of telehealth and other communication technology-based services. Explore this page for guidance on use of remote communication technologies for physical therapist services, and see our coronavirus webpage for updates related to the pandemic. Please beware of misinformation circulating online and via social media, including confusion about a new CMS rule that stops short of allowing PTs to conduct real-time "face-to-face" telehealth services.
Different Telehealth Modalities and PTs' and PTAs' Eligibility to Use Them
Telehealth is the use of electronic information and telecommunication technologies to remotely provide health care information and services. In some cases services are reported using the same codes that describe services typically provided in person but instead are being furnished "face to face" remotely using real-time audio and video with the PT observing the patient and providing cues based on the patient's movement or actions. As of now, Medicare does not cover these types of telehealth services when provided by PTs and PTAs, which typically entail using codes in the 97000 series. (Scroll down to "Advocacy: Use Your Voice To Call for Expanded Use of Telehealth" to help the profession advocate for face-to-face real-time telehealth services provided by PTs and PTAs.)
However, a recent CMS rule in response to COVID-19 makes it easier for PTs to furnish certain services using other forms of telehealth that don't entail live face-to-face interaction. These include e-visits, virtual check-ins, remote evaluation of recorded video and/or images, and telephone assessment and management (medical discussion) services. Some of these modalities are conducted in real time (but without face-to-face technology) while others use "store-and-forward" technologies, which allow for asynchronous electronic transmission of medical information, including documentation, digital images, and prerecorded videos.
Also in response to COVID-19, some commercial payers are covering telehealth services furnished by PTs and PTAs via live "face-to-face" video/audio and other forms of remote care. You'll need to first determine if your state practice act enables you to legally provide services via telehealth and, second, check with each payer policy to see if PTs and PTAs are included as providers eligible to be paid for telehealth services.
Before you begin providing services via telehealth or using telecommunications modalities, consider federal and state legislation and regulations that govern your practice, risk-management implications, billing and coding issues, and hardware/software requirements. The resources below identify areas most important for you to investigate and consider.
Telehealth Modalities PTs and PTAs Can Use During the Public Health Emergency
Medicare and some commercial payers are covering various forms of telehealth, including e-visits, virtual check-ins, and other remotely furnished services. (April 7, 2020)
Thinking About Providing Telehealth? Here's Our Top 10 'To-Do' List
Step 1 is knowing what's allowed, and what isn't. (March 27, 2020)
Asking the Right Questions About Telehealth
It's not enough to ask if telehealth is permitted by a state agency or payer: You need to ask specific questions to understand what you can and can't do.
New CMS Rule Includes Therapy Codes in Telehealth, Stops Short of Allowing PTs to Conduct Telehealth Services
CMS has announced "sweeping" temporary changes that give a nod to the potential for true telehealth by PTs even though regulatory barriers still prevent that from happening. Could it be a sign of more to come? (March 31, 2020)
Furnishing and Billing E-Visits: Addressing Your Questions
Recent waivers by CMS that allow for limited digital communication with patients have triggered a wave of questions. Here are our answers to our top 50 questions. (March 30, 2020)
Telehealth in Physical Therapy In Light of COVID-19
The coronavirus pandemic demands that health care providers rethink how they deliver care in ways that reduce risk of further spreading infection. (March 16, 2020)
Interactive Audio and Video Telecommunications System Matrix
APTA's Health Policy & Administration Section Technology SIG and the APTA FiRST Council have created a matrix of vendors that provide audio and video telecommunications services that could be used for telehealth and e-visits.
Courses and Webinars
Digital Telehealth Practice - Connect for Best Practice, Compliance, and Healthcare
This live Q&A on April 7, 2020, will include the latest updates on telehealth. Free to APTA members!
Implementing Telehealth in Your Practice STAT: Practical Guidance from Experienced Telehealth PTs
Provides insights into current practice models and clinical decision making in digital care delivery. Free to all!
Additional Free Courses From the APTA Learning Center
The opportunities include both live and recorded telehealth webinars.
Check on the Status of State Emergency Mandates and Payers Allowing Telehealth
As things rapidly develop regarding the COVID-19 pandemic, mandates and payer policies around telehealth and e-visits are continuously evolving. APTA has developed a series of summaries of the status of federal, state, and commercial payers regarding eligibility of PTs to provide telehealth services and payer coverage of some form of telehealth or e-visits during the COVID-19 pandemic, based on information the states and payers have released. APTA will update these resources weekly with new information that has been confirmed. These are summaries only; refer to the payer policies and state laws for the most accurate and current information.
Aetna Now Covers Telehealth Delivered by PTs
Aetna joins UnitedHealthcare among the commercial insurers that have expanded coverage from more limited e-visit provisions. (April 2, 2020)
UnitedHealthcare Allows Telehealth for Physical Therapy
Beginning immediately, the payer will reimburse physical therapy delivered via telehealth services. (March 27, 2020)
COVID Stimulus Package Includes Payment Increase, Opens Possibility of Increased Telehealth
An increase to Medicare payment, temporary relief for some student loans, the potential expansion of telehealth allowances, and help for small businesses are among the provisions that are especially relevant for physical therapy. (March 27, 2020)
Advocacy: Use Your Voice To Call For Expanded Use of Telehealth
On March 27, APTA joined AOTA and ASHA in calling on CMS to use its 1135 waiver authority to meet the medically necessary needs of Medicare beneficiaries by immediately expanding Medicare coverage of telehealth services to include audiology, occupational therapy, physical therapy, and speech-language pathology.
Use these template letters to advocate for telehealth. Instructions are included at the top of each letter.
Additional Guidance on Practicing Via Telehealth
Before adopting any telehealth solution, investigate issues such as eligibility under your state's practice act, legal and privacy considerations, payer policies, and liability; and review practical considerations for when you begin using telehealth services. Please note: The information provided is offered for general informational purposes only. It is not offered or intended, nor should it be relied upon, as legal advice. Legal doctrines, statutes, and case law vary from state to state. You should consult with your own attorney for specific legal advice on particular legal issues.
Here are some things to consider:
Eligibility, Compliance, and Payment
- Check your state practice act to verify that you can provide telehealth services in your state. Your state recently may have changed regulations (or may in the near future) because of the COVID-19 pandemic, so ask now even if your state previously prohibited or was silent on it. APTA provides links to all state practice acts.
- Document the legal and ethical reasons you are converting patients to telehealth visits. While the COVID-19 pandemic offers a good reason, you still need to document.
- Have your legal team review and approve your emergency policies and procedures. (Example: If your patient falls at home while you are working with them, what process do you have in place to address this emergency?)
- Contact and contract with private payers regarding being eligible for payment for furnishing, implementing, and using telehealth to provide services.
- Use secured portals and have Business Associates Agreements in place with your telehealth vendor and any other related business associates.
Liability and Informed Consent
Check with your malpractice insurance carrier for any coverage policies specific to telehealth and e-visits prior to providing physical therapy using these modalities. APTA advises all PTs, PTAs, and students to have professional liability insurance from Healthcare Providers Service Organization. HPSO provides a helpful article titled "Telemedicine: Risk Management Issues, Strategies and Resources (.pdf)."
You must get consent from each patient, with right to refuse, and give them the option to be seen in the office. Include the patient's consent in your documentation. Additionally, before conducting services via telehealth and e-visits, consult your state practice act, state law, and individual payers for any informed consent requirements. Some jurisdictions require informed consent only on the first telehealth visit, while others requiring it after every visit. Some explicitly require physical therapists to obtain informed consent before practicing telehealth, while others require informed consent for all providers practicing telehealth. The Center for Connected Health Policy provides a report on telehealth laws and policies (.pdf) and resources on informed consent.
- Determine your primary needs. For example, if you want to provide live video visits, then you will look for a telehealth product with strong live video capabilities. If your primary goal is to increase communication with patients, you may want to choose a product with a secure texting solution.
- Learn how to use your technology. Practice using the equipment with your colleagues to understand the technology and to learn the multi-tasking skills needed.
- Prepare policies and procedures before you start. Have contingency plans for what to do if, for example, you lose audio or video connectivity, the internet stops working, the patient has additional complications while you are working with them, or your patient decides they don't want to proceed with telehealth services.
- Get the highest bandwidth internet connection you can. Consider having a backup with a different type of system. For example, if your main connection is fiber optic, use cable or DSL as a backup.
- Be aware of your surroundings and determine if you're in the best surroundings to conduct telehealth visits. You and the patient should be somewhere quiet and with good, even lighting so you can hear and see each other. Other people should not be nearby you or, ideally, your patient, as this is a HIPAA breach.
- Be wary of sub-optimal telehealth platforms. Use due diligence in researching the vendors you're considering.
- Maintain a hybrid approach of telehealth and in-office visits when possible.
Telehealth Ethics, Best Practice, and the Law: What You Need to Know
As physical therapist practice expands to include telehealth, securing patients' protected health information (PHI) is more critical than ever before. (August 28, 2019)
Why Use Telehealth
The complex US health care system is under a tremendous pressure. Many traditional health care business models are designed to allow high-volume, low-cost procedures to offset the costs of low- volume, high-cost procedures. An upward shift in the aging population is projected to result in a large increase in demand for health care, and new legislation such as the Affordable Care Act has added uncertainty to the future of health care business models and payment.
In physical therapy, our patients/clients are asking for more time-efficient and less costly care models. Their busy lifestyles also can make it difficult for them to attend traditional appointments.
Applications of telehealth in physical therapy already have roots that expand throughout patient/client care and consultation, as it allows PTs to better communicate with patients/clients and provide more flexible care. Telehealth will not replace traditional clinical care. However, it will give PTs and PTAs the flexibility to provide services in a greater capacity. Examples:
- Patients typically in clinical or hospital settings could be managed from their homes
- Quicker screening, assessment, and referrals can improve care coordination within collaborative delivery models such as accountable care organizations or patient-centered medical homes
- Telehealth can facilitate consultation between providers or in clinical education
Increasing Access to Physical Therapist Services: Research on Telerehabilitation (.pdf)
This issue brief contains information on studies that demonstrate the potential for cost-savings, improved outcomes, increased access, and higher patient satisfaction through the use of telerehabilitation.
Telehealth in Action: Physical Therapists Share Their Stories (.pdf)
Get first-hand accounts of how PTs are providing physical therapist services via telehealth to clients and patients.