NOTE: Scroll down the page for information on how to advocate for loosening restrictions on PT and PTA use of telehealth, and on using e-visits to provide services. 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, visit our Coronavirus webpage.
Telehealth, the use of electronic communication to remotely provide health care information and services, is gaining more and more attention as providers, patients, and payers all seek more effective and cost-efficient ways to deliver care. Physical therapy is no exception, and while those services have developed mostly in rural areas to accommodate the long distances between patients and providers, telehealth in physical therapy is being considered in other geographic and clinical settings.
This isn't to say that you should jump right in and begin providing services via telehealth. You'll first need to 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 aren't meant to give you detailed instructions on developing and using telehealth in your practice, but they identify areas most important for you to investigate and consider.
News and Updates
March 23, 2020, Update:
APTA recommends asking these specific questions when you communicate with a payer or state agency about whether telehealth is permitted for physical therapist services. ALSO: 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. (Learn more about the FiRST Council below.)
March 20, 2020, Update: APTA has developed two template letters to use in advocating to states — your governor, state representatives, and Medicaid office director — for coverage by private payers and Medicaid 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. One letter is for individual PTs and PTAs; the other letter is for state chapters. Instructions are included at the top of each letter.
View more Coronavirus (COVID-19) updates.
Tell CMS, states, and payers to waive restrictions on the 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.
APTA has created several tools you can use to advocate for coverage of telehealth services furnished by PTs and PTAs to ensure that patients continued to have access to the rehabilitative care they need amid the COVID-19 pandemic. For the template letters, instructions are included at the top of each letter.
Check on the Status of Payers That Cover 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 that are covering some form of telehealth or e-visits during the COVID-19 pandemic, based on information the states and payers have released. APTA will continue to update these resources when new information is confirmed. These are summaries only; refer to the payer policies and state laws for the most accurate and current information.
E-Visits vs. Telehealth
CMS has waived certain restrictions on digital communication in light of the COVID-19 pandemic. An e-visit is described by CMS non face-to-face patient-initiated digital communications that require a clinical decision that otherwise typically would have been provided in the office. The code descriptors for the HCPSC codes related to e-visits (G2061, G2062, and G2063) suggest that the codes are intended to cover short-term (up to seven days) assessments and management activities that are conducted online or via some other digital platform and include any associated clinical decision-making.
Under Medicare, while an e-visit is considered a service furnished remotely using technology, it does not constitute a telehealth service. The answer varies under commercial payer policies, so check with each carrier for coverage, coding, and billing requirements related to e-visits. Learn more about e-visits.
Furnishing and Billing E-Visits: FAQs
(Updated March 20, 2020)
Along with a comprehensive list of questions to guide you through the process, this article opens with an overview and links to two recent APTA online recorded presentations: a town hall with accompanying slide deck and a Facebook Live event.
CMS Moves to Allow Digital Communications by PTs (PT in Motion News, March 17, 2020)
The new regulatory waivers will allow PTs, OTs, and SLPs to engage in patient-initiated "e-visits" for purposes of assessment and management services.
Before You Begin 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. Here are some areas to consider:
Eligibility, Liability, 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.
- You must get consent from each patient, with right to refuse, and give them option to be seen in office. Include the patient's consent in your documentation.
- 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.
Review your malpractice insurance policy to verify that you are covered for telehealth services. HPSO provides a helpful article titled "Telemedicine: Risk Management Issues, Strategies and Resources (.pdf)."
- 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. For example:
- You and the patient should be somewhere quiet. Places with significant background noise will make it hard for you to hear each other.
- Use good, even lighting. Having your back to a window or other light source will put you in shadow and might force your patient to look into the sun. If your patient is in shadow, you won't be able to properly assess their appearance and movements.
- 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.
HIPAA and Telehealth
A free APTA Learning Center webinar that discusses what physical therapists need to know to ensure compliance with regulations established by HIPAA and the APTA Code of Ethics when using telehealth and mobile health technology. This webinar is not intended to cover every legal, ethical, or practice consideration.
HPA the Catalyst Technology Special Interest Group
Provides a forum for Health Policy & Administration members with a common interest in technology.
Telehealth Ethics, Best Practice, and the Law: What You Need to Know
Blog highlighting ethics, best practice, and law considerations for practicing Telehealth.
Telehealth and Physical Therapy: Merging of Practice and Technology in the New Frontier
Purchase this course to learn what you need to know in order to implement telehealth into your practice. This course is co-sponsored by HPA the Catalyst.
APTA Position Paper on CONNECT for Health Act (.pdf)
APTA supports the Creating Opportunities Now for Necessary and Effective Care Technologies (CONNECT) for Health Act of 2019 (H.R. 4932/S. 2741), legislation that would expand the use of telehealth services and ease restrictions on telehealth coverage under the Medicare program.
Why Use Telehealth
The complex US health care system is under a tremendous amount of 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. Telehealth is projected to grow worldwide to 1.8 million users by 2017, according to the World Market of Telehealth.
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.
Telehealth and the FiRST Council
Telehealth is part of APTA's Frontiers in Rehabilitation, Science, and Technology (FiRST) Council. FiRST grew out of identification of high priority areas to advance science and innovation that our profession needs to understand and incorporate into our practice, education, and research.
FiRST is intended to serve as a community for interested stakeholders. Ideas generated by the council may be implemented by participants' stakeholder groups (sections, academies, external groups, APTA, etc) at the discretion of each entity's governing body.
Telehealth in Physical Therapy: CSM 2014 Video Interview