NOTE: Official guidance and best practices related to telehealth and e-visits could change rapidly as the COVID-19 outbreak continues to evolve. For the most current information from APTA, see our main Telehealth webpage and visit our Coronavirus webpage.
APTA has developed a template letter for you to use in advocating to your payers (.docx) — private, Medicare Advantage, and Medicaid (both fee for service and MCOs) — for coverage of telehealth furnished by PTs and PTAs to ensure that patients continue to have access to the rehabilitative care they need amid the COVID-19 pandemic. Instructions are included at the top of the letter.
Billing physical therapy services that have been provided through telehealth is an emerging challenge, partly because there are as of yet few precedents on which to base claims review. As more PTs use and bill for telehealth, payers will become more familiar and comfortable with negotiating rates for telehealth services.
Below is a snapshot of the current trends in billing and coding for physical therapist services provided via telehealth and provides basic recommendations.
Medicare does not pay for telehealth provided by physical therapists.
During the COVID-19 national health emergency, Medicare pays for real-time face-to-face telehealth furnished by PTs and PTAs in private practice under Medicare Part B.
Through an interim final ruling released April 30, CMS temporarily expanded its list of approved provider types that can furnish telehealth services to include all providers who are eligible to bill Medicare for their professional services — adding PTs, OTs, and SLPs to the list. The ruling is retroactive to March 1, 2020.
Information on aspects of telehealth eligibility for PTs and PTAs are outlined in this May 6 APTA news item, including provision of services by PTAs, the possibility of "direct supervision" being allowed to be conducted via real-time interactive audio and visual communication, and the potential for hospital-employed PTs and PTAs to furnish telehealth services to hospital outpatients in their homes.
Medicaid does pay for telehealth for PTs but not in all states.
Check with your state Medicaid agency before you bill for services to confirm whether or not your state's program currently reimburses for telehealth for PT services.
During the national health emergency, APTA is maintaining a list of federal payers, including Medicaid, that have made at least temporary policy revisions to cover telehealth services (.pdf) provided by PTs and PTAs. Please check with your state Medicaid agency before you bill for services.
Medicaid policies on the originating site and real-time vs asynchronous services also differ among states, so check your state's policy.
Third-party payment for telehealth depends on your contract with your payer.
During the national health emergency, APTA is maintaining a list of commercial payers that have made at least temporary policy revisions to cover telehealth services (.pdf) provided by PTs and PTAs. However, there is no list of third-party payers that pay for telehealth, so check with each payer. Also confirm with each payer whether the originating site can be a private home or office, if services must be real-time or can be asynchronous, and any other limitations to your use of telehealth. Review other considerations when billing for telehealth.
For billing, there are no "telehealth" CPT codes.
But before reporting CPT codes you traditionally use for clinical visits, check with your payer. Many of the physical medicine and rehab codes (97000 series) specify "direct 1-on-1 patient contact," which by strict definition would exclude telehealth unless you and your payer have agreed to include these services. A payer also may require an addendum attached to the bill that identifies the service as being provided via telehealth, along with an explanation of the charges, so be prepared to outline the reasoning for using telehealth.
You also should check with your payer about using place-of-service code "02" when billing for telehealth services to specify the entity where service(s) were rendered.
Regardless of the payer or policy, if you provide and bill for services using telehealth, make sure that you are practicing legally and ethically, and are adhering to state and federal practice guidelines and payer contract agreements.