On July 23, amid a still-growing coronavirus pandemic, U.S. Department of Health and Human Services Secretary Alexander Azar renewed the HHS public health emergency, or PHE, declaration.
The HHS renewal means that Medicare telehealth flexibilities, as well as many of the other temporary policies implemented by CMS during this PHE, will continue so long as both Secretary Azar’s declaration and the president's national emergency declaration continue.
Given that it's been nearly six months since the first PHE was declared (it's been renewed twice since then), now may be a good time to get reacquainted with exactly what the flexibilities mean for PTs and PTAs, particularly around the use of telehealth.
Here are our tips and top resources to help you to stay up-to-speed on the PHE and telehealth.
1. Go to the source: Find out what CMS has to say about the PHE in its own words.
The CMS "Coronavirus Waivers and Flexibilities" page is a must if you want the most complete understanding of what the PHE means for PTs, PTAs, and their patients — at least in terms of federal payment. Yes, CMS-speak can be hard to wade through at times, but this is the basis for just about every interpretation of what PTs and PTAs can and can't do (and get paid for)
2. Find out how telehealth could work in your practice (or if you're already using it, find out if you need to adjust your approach).
Changes to coding and billing during the PHE are a big part of the new landscape PTs and PTAs are facing, but there are other considerations to take into account. These resources can help you identify practice and patient considerations as well as payment requirements.
- Telehealth in Practice. Our general telehealth webpage is a good place to start: It includes links to not just state and federal regulatory information, but insight on practice considerations and links to quick guides to remote evaluations, virtual check-ins, and e-visits.
- Implementing Telehealth Into Your Practice. You can access this page through our general telehealth page, but here's the direct link. This resource underscores the idea that providing services via telehealth isn't just a matter of firing up your laptop: you need to take into account eligibility, liability, technology, and practice considerations.
- Telehealth Modalities PTs and PTAs Can Use During the Public Health Emergency. Know your e-visit from your virtual check-in, and how they're both different from real-time interactive communications. This page gets into the details about the different ways you can work with patients remotely.
3. Understand the federal and commercial payer landscape.
The PHE created ripple effects in the payment world beyond Medicare. Both federal and commercial payment systems have adjusted — sometimes in different ways — and it's crucial to stay on top of the changes.
- Federal Payer Telehealth and E-Visit Coverage. This regularly updated resource tracks how federal programs such as TRICARE, Health Net, Humana Military, and Medicare have adjusted their payment policies for telehealth services in light of the PHE.
- Commercial Payer Telehealth or E-Visit Coverage. Similar to the federal payer resource, this document tracks what commercial insurers such as Aetna, Anthem, United HealthCare and many more are doing to adjust payment policies during the PHE.
4. Appreciate the power held by state governments.
It can't be stressed enough: Individual states are the decision-makers around much of what PTs and PTAs can and can't do in response to the COVID-19 pandemic. These regularly updated resources can help you make fact-based practice decisions.
- Telehealth State Regulations and Legislation. It's critical to review your state's laws and regulations, physical therapy practice act, and Medicaid and private payer coverage policies to determine any limitations to using telehealth in the state or district in which you practice. This page provides the basic background you need.
- State Laws Related to Commercial Payer Telehealth Parity. Some states have laws that govern how commercial payers provide coverage and payment for telehealth visits compared with in-person visits. The scope of these laws varies widely. This regularly updated document connects you with the relevant state laws.
- State-Level Actions Related to Nonfederal Payer Coverage of Telehealth. This regularly updated chart tracks and links to state actions related to Medicaid, commercial, and workers’ comp coverage of telehealth as a result of the COVID-19 crisis.