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  • CMS Moves to Allow Digital Communications by PTs

    The new regulatory waivers will allow PTs, OTs, and SLPs to engage in patient-initiated "e-visits" for purposes of assessment and management services.

    In the federal government’s rapidly evolving response to the coronavirus pandemic, the U.S. Centers for Medicare and Medicaid Services has announced that it is easing Medicare telehealth restrictions in ways that could allow PTs to provide "e-visits," a limited type of service that must be initiated by the patient. Prior to this change CMS did not recognize PTs among the health care professionals allowed to bill codes associated with the visits.

    The change, announced midday on March 17, is part of a set of loosened requirements that CMS has adopted to expand the provision of telehealth and patient-initiated digital communications, such as e-visits, to help blunt the spread of COVID-19. For the most part, PTs remain outside the reach of these so-called "1135 waivers" related to telehealth, with one exception: a type of remote interaction CMS calls an e-visit under Medicare Part B.

    In its 2020 physician fee schedule final rule, CMS describes e-visits as “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 suggest the codes are intended to cover short-term (up to seven days) assessments that are conducted online or via some other digital platform, and include any associated clinical decision-making.

    Under the waivers guidance issued by CMS, Medicare beneficiaries can qualify for e-visits no matter their geographic region or physical location, meaning that the provisions have been expanded to nonrural areas and can take place with patients in their homes. The big news for PTs and their patients is that, for the first time, PTs will be allowed to bill for e-visits under codes associated with online assessment and management services (codes G2061, G2062, and G2063). To determine the reimbursement rates for G2061-G2063, visit the CMS Physician Fee Schedule lookup tool. Medicare coinsurance and deductible would apply to the services. A March 18 CMS MLN Matters article includes more information about the e-visits and telehealth waiver.

    To qualify as an e-visit, three basic qualifications must be met: the billing practice must have an established relationship with the patient, meaning the provider must have an existing provider-patient relationship; the patient must initiate the inquiry for an e-visit and verbally consent to check-in services; and the communications must be limited to a seven-day period through an "online patient portal."

    Although the patient must initiate, CMS writes in a fact sheet that "practitioners may educate beneficiaries on the availability of the service prior to patient initiation." For example, if a patient cancels treatment because they can’t come to the clinic or are concerned about leaving home, then the PT may advise the patient that she or her can reach out to the therapists as needed.

    Alice Bell, PT, DPT, APTA senior payment specialist, says that the waiver has some very practical implications for PTs, and offers a possible scenario in which the e-visit could be useful.

    "Let's say that, as a PT, I've been seeing a patient for an orthopedic condition and I am progressing the patient’s exercises," Bell said. "The patient is unable to come into the clinic but calls me to say she's having difficulty with one of the exercises and that the other two seem to be too easy. I could arrange an e-visit with the patient and discuss her performance of the exercises. And I could then make a determination — maybe I find that the patient is performing one of the exercises incorrectly — and I could direct the patient on the correct performance. Perhaps I also determine that two of the exercises can be progressed because the patient is improving, so I could instruct the patient in the two new exercises. After that I could advise the patient to contact me for a follow-up e-visit as needed until the patient can return to the clinic."

    The HHS Office of the Inspector General has also issued a policy statement that provides guidance on how it interprets the new telehealth waivers. APTA regulatory affairs staff will continue to monitor these waivers and other developments and share news with members.

    "As we've seen over the past few weeks, and especially during the past few days, we're dealing with an extremely fluid situation in terms of response to the coronavirus pandemic," said Kara Gainer, APTA's director of regulatory affairs. "This waiver and other changes have the potential to make a difference, and we hope that CMS continues to take steps that can help providers and their patients stay healthy."

    APTA has issued a statement on patient care and practice management during the COVID-19 outbreak, and offers a webpage to keep members up to date with the latest news on the pandemic.


    • Do we know if the "7 days" refers to 7 consecutive days or do they mean up to 7 different visits spread out?

      Posted by Melanie A Gagnon on 3/17/2020 4:25 PM

    • Congratulations to the APTA staff who have worked very hard to accomplish this. Thank you for all you do and all your help! Although this CMS initiative does not address the current and future issues of TelePT in its totality, this is a step in the right direction Let's now aim towards the next step in this issue which is: to allow the performance of most PT codes in a telePT capacity. Treating these people for 7 times and just in a supplementary capacity to the face to face treatment does not solve the problem. What happens to people who cannot even go to an office or outpatient hospital department and what happens to them if they cannot secure home therapy? We need to seriously look into that and allow Evaluation and treatment in a remote capacity and reimburse to the PTs the regular eval and treatment codes Thank you again. Dimi

      Posted by Dimitrios Kostopoulos on 3/17/2020 6:02 PM

    • Seven days is limited for a course of therapy that normally lasts several weeks. This is not very useful to patients who may be shut in for weeks or months without much activity. Many elderly are not capable of self motivating and remembering exercise and there is no allowance for progression.

      Posted by lisa janani on 3/17/2020 6:45 PM

    • What happens after the seven days? For example we see the patient Monday and Wednesday of the first week of April, what happens after the first week of April?

      Posted by Kristin Terkelsen on 3/17/2020 6:47 PM

    • Are the codes timed? Based on the 8th minute rule? How many codes can we bill per visit?

      Posted by George Adamakis on 3/17/2020 6:48 PM

    • I sincerely hope that the industry will keep pushing for more. This very limited type of interaction will not assist our many patients that for their own health do not wish to come into an office at this time. We need the same regular telehealth visit that other provider types are allowed.

      Posted by Laura Peltz on 3/17/2020 6:50 PM

    • This is great news however it seems extremely limiting if only allowed for 7 days. What happens after that? Zoom has a HIPPA compliant TELEHEALTH program but require a 12 month contract. This won’t work for me! Does anyone else have a suggestion for a HIPPA compliant Telehealth provider? Telehealth is. A must for our patients!!! No one cares for them or helps them in the way we can!

      Posted by Margaret FItzpatrick on 3/17/2020 7:55 PM

    • So for clarification, we currently cannot see any new evaluations via telehealth? A new patient who has just recently had a orthopedic outpatient procedure would not be eligible for intervention via Tele health?

      Posted by Joseph Powell, DScPT on 3/17/2020 7:58 PM

    • This is a great benefit to properly progress post surgical patients, current patients and patients that have just been evaluated to have safe continuity of care.

      Posted by Jim on 3/17/2020 8:14 PM

    • What kind of documentation or evisit platform is required for Medicare reimbursement? Does the evisit need to be recorded or just documented?

      Posted by Sung Kim on 3/17/2020 10:21 PM

    • I see that most HIPPA issues waived and facetime and skype can be used at this time. Does that mean it also waives that a provider/physical therapist has to be in clinic or can you be in a home office that no one else can hear me in?

      Posted by Jennifer on 3/18/2020 1:59 AM

    • Thank you for liberalizing that we could bill for services via telemedicine. Would it not be prudent to check if the licensing to practice via telemedicine has been liberalized for current emergency need?

      Posted by Carol on 3/18/2020 6:53 AM

    • Please allow telehealth PT visits or virtual to stay safe during this pandemic

      Posted by Diane Marshall on 3/18/2020 6:59 AM

    • The article does not mention assistants. Are we not able to digitally treat a patient?

      Posted by Thomas Brown on 3/18/2020 8:26 AM

    • Is an e-visit considered just written communication via a patient portal or does it include video conferencing and actual treatment over a device?

      Posted by Kathleen Parisian on 3/18/2020 8:30 AM

    • Also, is there any specificatons on how the e-visit is to be conducted. I live in an area where it is primarily senior citizens who do not have access with technology so skype/facetime/video conferencing may not be possible. Will a phone call be considered a billable session?

      Posted by Gary on 3/18/2020 8:48 AM

    • What technology can we use to connect with the patient?

      Posted by Kavitha on 3/18/2020 9:12 AM

    • Can ptas participate and bill with this? Are we limited to one week only?

      Posted by Mike on 3/18/2020 9:15 AM

    • The way I'm reading it is that an e-visit can be charged for a maximum of 21 or more minutes during a 7 day period (G2063). So that would be equivalent to providing one e-health visit per week. I don't interpret it as there being a limit on the number of e-health visits as long as the visit is consistent with the plan of care.

      Posted by John Ware on 3/18/2020 9:31 AM

    • How about when it comes to early intervention in NYS-home based care? Any updates or guidelines being considered?

      Posted by Aida Martinez on 3/18/2020 9:40 AM

    • Can we get some clarification on the 7 days?

      Posted by Ross White -> AMV]DG on 3/18/2020 9:45 AM

    • Does this require a video call or can this just be done with a normal phone call? Does this mean you can bill 1 code every 7 days per patient (meaning you could bill 4 codes per month) or does this mean you can only bill one code for services which can only last 7 days? Thank you!

      Posted by Ryan Willis -> ALPZ>F on 3/18/2020 9:51 AM

    • Are there any guidelines regarding the specific types of devices used to conduct the e-visits?

      Posted by Carmen Vitton on 3/18/2020 10:09 AM

    • Can PTs continue to bill the 97000s codes and just specify that services are provided via telehealth by selecting '02' as the location on the billing sheet?

      Posted by Heather Popp -> @OT^AG on 3/18/2020 10:14 AM

    • Or does it mean only 1 e-visit visit every 7 days.

      Posted by James Kinton on 3/18/2020 10:26 AM

    • Language in the first paragraph says 'could' allow; is there further legislation pending or is this affirmative given acceptability per state practice act?

      Posted by Carmen Vitton on 3/18/2020 10:29 AM

    • Does this pertain to home health visits as well for our skilled PT doing only home care under medicare part A

      Posted by Debbie Rumowicz -> @HVc on 3/18/2020 10:38 AM

    • Is there a definition or description of "online patient portal."?

      Posted by David Miller -> =NR_= on 3/18/2020 10:48 AM

    • Also do we know if this applies to phone conversations? Or does there have to be a video component as well?

      Posted by Samantha Bair-Jones on 3/18/2020 11:15 AM

    • Does this require a video interaction or can this be done with a normal phone call? And if talk Does the 7 day period mean that if you spend >21min over that period, then you can bill a new code every 7 days (meaning 4 codes per month potentially)? Or does that mean from first contact to last contact with the patient you get 7 days to provide more than 21 minutes of services? I agree that the wording suggests only 7 days but never says we can't bill more than 1 code over the patient's episode of care

      Posted by Ryan Willis -> ALPZ>F on 3/18/2020 11:25 AM

    • * Please can you clarify what platforms are considered HIPAA compliant? Or can you send me the article where I can read that FaceTime, Skype, Jituzu etc are considered safe platforms? * Clarifying 7 different days, or consecutive days would be good. * Evaluations (Speech, not PT/OT) can NOT be performed via telemedicine? * This is Medicare only? Do we know if Medicaid and the private insurances are being asked to offer the same?

      Posted by Clare on 3/18/2020 11:38 AM

    • Do you need to have video component to the telehealth or can this be done just over the phone? Confusing how they determine that.

      Posted by Ryan Mahar -> =NTaCK on 3/18/2020 11:44 AM

    • Has CMS been approached to extend this to Home Care Medicare Part A billing?

      Posted by Raymond Bilecky -> >OP\C on 3/18/2020 12:11 PM

    • Awesome start. SO many questions- all of mine have already been asked. platform? one every 7 day? PTA? Medicare online? thanks for more!

      Posted by Dunya Dubovenko on 3/18/2020 12:55 PM

    • So these can only be done through a patient portal--how do we set that up and then is there just a link in the portal for Skype or facetime?

      Posted by Melissa Baumgartner -> =LV\EM on 3/18/2020 1:47 PM

    • From what I've researched for other providers for telehealth the coding is for a the cumulative time provided in a 7 day period. As in the example above you would advise your patient to let you know if they needed follow up and if so, then they could schedule another evisit. We've been looking at HIPAA compliant platforms and doxy.me seems to be the most user friendly and is free. I've also been told that we would use our regular coding since it is in parody to what we provide in office. However, you would bill with the POS as 02. I've also read in a couple of our insurance contracts that we would append modifier GT (and/or 95) to show synchronous visit. I am still researching and if anyone knows if the above is correct or NOT correct, please let me know! I also found this online that describes the coding a little better...I do not work for anyone mentioned in this post! :) https://codingintel.com/cpt-codes-online-digital-evaluation-and-management-services/

      Posted by Catrina on 3/18/2020 1:53 PM

    • I treat students in the school systems and we base our treatment time and frequency according to students IEP (individual education plan). My treatments state in the IEP that I treat the student 30 minutes weekly. Do I need to stay on the phone with the student/parent for the duration of the 30 minutes?. Example.. I am treating a student that is in FMD and he/she has difficulty staying on the phone for 30 minutes. Is this neglecting the IEP? Is this still a Billa treatment?

      Posted by Kimberly Minor on 3/18/2020 1:53 PM

    • Can PTA's treat Medicare patients via Telehealth.

      Posted by Richard Roll on 3/18/2020 2:51 PM

    • Same question as above. Sounds like 7 consecutive days. What happens after that? NO more visits allowed? Billing question--Only put one code G2061-G2063 no 97110, 97112, 97530 at all? Previously, I read modifier GT was applied, Is it still relevant? would commercial insurances accept G2061-G2063 or should we continue regular PT CPT codes plus GT modifier? Commercial insurances are clueless about PT and telehealth .

      Posted by Inna Keselman on 3/18/2020 3:06 PM

    • Is this nationally recognized, or are we limited by State rules?

      Posted by Katie van den Heuvel on 3/18/2020 3:34 PM

    • Can you please advise documentation guidelines for an E-visit?

      Posted by Toni on 3/18/2020 6:31 PM

    • Poorly written article that gives us more questions than anything else.

      Posted by JOHN W WISE on 3/18/2020 6:39 PM

    • BlueJay's technologies have been developed to help PTs to do e-visits (telehealth, sending HEP videos, tracking outcomes etc.). We also build telehealth scheduler on clinics' websites such that patients can initiate the e-visits easily. This legislation ushered in a new era for PTs to deliver care online.

      Posted by Tony Zhang on 3/18/2020 6:52 PM

    • Thank you APTA for getting the ball rolling in a time of need.

      Posted by Christine on 3/18/2020 6:54 PM

    • Also trying to figure out what the 7 days statement refers to, my interpretation of the way the codes are written in the CMS fact sheet is "total time over a period of 7 days" to decide which billing code to appropriately bill. Meaning that code is billed for a period of 7 days and then the clock resets for another 7 days and you choose the most appropriate code. Essentially limiting the codes to a week of time versus 1 session. Really need to see more information on this and some guidance from the APTA. Here is how it is written in the CMS fact sheet: G2061 - Qualified non-physician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the 7 days; 5–10 minutes G2062 - Qualified non-physician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 11–20 minutes G2063 - Qualified non-physician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 11–20 minutes.

      Posted by Michael Groesch on 3/18/2020 9:05 PM

    • My VoIP phone system works via the Internet, not via old-fashioned copper telephone wires. Therefore, based on the wording used, my phone system is an online patient portal.

      Posted by Tim Richardson on 3/19/2020 8:28 AM

    • is patient initiation required for telehealth visits too?? I see that it is a requirement for E-Visits and Virtual Check Ins, but what about telehealth?

      Posted by heather on 3/19/2020 10:34 AM

    • I guess it is step in right direction but a max of about $35 for >20 min over a 7 days period doesn't solve many problems.

      Posted by Craig on 3/19/2020 11:58 AM

    • I want to know How much I will be paid for an evaluation. I have tried to read through the goobly goook and i cannot find any straight talk. And can we bill units besides the eval.

      Posted by Jennifer White on 3/19/2020 3:35 PM

    • I think it is important to understand what a "patient portal" is and isn't. https://www.healthit.gov/faq/what-patient-portal Most providers don't understand the difference between using a videoconferencing software or chatroom or APP or website or portal.

      Posted by Tammy Richmond on 3/19/2020 8:47 PM

    • Does this include medicare replacement insurance

      Posted by Howard Yap on 3/19/2020 8:59 PM

    • good first step

      Posted by David Woods -> DMR_AL on 3/20/2020 9:45 AM

    • Thank you for still helping patients during this crisis.

      Posted by Carol Allen on 3/21/2020 9:48 AM

    • What platforms can you use to provide e-visits if skype and facetime is not allowed?  Our clinic does not have access to a patient portal.  Why does the directive about HIPPA compliance not apply to physical therapists providing e-visits?

      Posted by Michael Groesch -> BKQ[@M on 3/21/2020 1:58 PM

    • I work in a school district and am wondering how this will work. We are doing virtual learning because every student has an iPad at home. I have to email the parents to let them know what their child is doing. I can not do FaceTime or Zoom to treat the students. Does email count? Can I bill for this time? My students are special education and most need assistance from an adult to use technology. Thanks!

      Posted by Diane Cashman -> =IXaDF on 3/22/2020 8:09 AM

    • Good morning! Any any updates on whether Telehealth is approved for Medicare beneficiaries?

      Posted by Haim Nesser on 3/23/2020 8:33 AM

    • I too work as a school based therapist. We will be doing video visits (Zoom, Facetime, etc) as well as phone calls and possibly pre-recorded sessions. This will go on for the duration of time a school is doing e-learning (not just 7 days). Has CMS given any guidelines for reimbursement of these services through medicaid?

      Posted by Shacorrah Evans on 3/23/2020 12:55 PM

    • It seems like everyone has the same questions that I do, without any clear explanations....

      Posted by John on 3/23/2020 1:09 PM

    • Your guidance is not up to date. There has been more released by CMS, and many private payers have different requirements for modifiers and what you can bill. Quite plainly, this is a complete failure by a governing body

      Posted by Paul on 4/2/2020 5:59 PM

    • @Paul: This story, dated March 17, was reporting on actions taken by CMS at that time. Since then, we've shared the latest developments from CMS as they are announced. Please visit our coronavirus page at http://www.apta.org/Coronavirus/ for a collection of relevant and frequently updated information.

      Posted by APTA staff on 4/3/2020 7:08 AM

    • As a PTA working for a homecare agency, what are the policies around that? Are PTAs allowed to bill for televisits?

      Posted by Gina R. Marshall on 4/7/2020 7:43 PM

    • @Michael: CMS has not indicated that there is any flexibility with the online patient portal requirement for e-visits. It’s possible that commercial payers may be more flexible in how e-visits are performed. The directive about the enforcement discretion of HIPAA requirements from the U.S. Department of Health and Human Services Office for Civil Rights would include PTs providing e-visits, however, keep in mind that that enforcement discretion is only for the duration of the public health emergency, and any state laws related to patient privacy and security still apply.

      Posted by APTA staff on 4/8/2020 8:32 AM

    • @Diane: Please refer to http://www.apta.org/PatientCare/COVID-19/PatientManagementPediatric/ and send any follow-up questions you may have to memberservices@apta.org.

      Posted by APTA staff on 4/8/2020 8:32 AM

    • @Sharcorrah: Various Medicaid programs have reimbursed for services provided through telehealth furnished by PTs for quite some time, but state policies are subject to change, so check with your state Medicaid agency before you bill for services to confirm whether or not your state's program currently reimburses for telehealth. Also, Medicaid policies on the originating site and real-time vs asynchronous services also differ among states, so check your state's policy. Prior to COVID-19, 9 states explicitly reimburse for telehealth for PT services; 11 states contain open language in state regulation or reimbursement policies that may allow for Medicaid to reimburse for telehealth for PT services. For details, see here. In light of COVID-19, more states have mandated coverage of physical therapy under Medicaid. See: http://www.apta.org/uploadedFiles/APTAorg/Practice_and_Patient_Care/Patient_Care/Technology/Telehealth/Coding_and_Billing/TelehealthCOVID19StateMandatedHealthOrders.pdf

      Posted by APTA staff on 4/8/2020 8:33 AM

    • @Gina: It is dependent on your state practice act, and whether your state practice act permits PTAs to furnish telehealth, and also payer policy. Some commercial payers may reimburse for home care visits furnished via telehealth. However, at the time of this writing, Medicare does not reimburse for home care visits furnished via telehealth. However, Medicare has said that “remote patient monitoring” is one type of service that can be furnished via a telecommunications system to augment a home health plan of care without substituting for an in-person visit. Moreover, for the duration of the PHE for the COVID-19 pandemic, CMS is amending its regulations on an interim basis to provide HHAs with the flexibility, in addition to remote patient monitoring, to use various types of telecommunications systems (that is, technology) in conjunction with the provision of in-person visits. The use of technology must be related to the skilled services being furnished by the nurse or therapist or therapist assistant to optimize the services furnished during the home visit or when there is a home visit.

      Posted by APTA staff on 4/8/2020 8:34 AM

    • Hi, any idea if the same POC rules 1 per 90 days) required ?

      Posted by Boris on 4/29/2020 3:06 PM

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