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Details are in short supply, but in a recent communication with APTA, CMS seems to say that a PT's evaluation or treatment visit via real-time video, if delivered to a patient in a different room of the same building, could be billed as in-person services.

During a national stakeholder call on April 8, CMS opened up the possibility that it would allow a clinician to provide services remotely to a patient in the same building, but not in the same room, and bill the encounter as an in-person visit. A follow-up question submitted by APTA via email seems to indicate that CMS thinks the allowance applies to PTs.

APTA provided two examples for CMS' consideration: a PT performing an evaluation via Facetime or Skype in the same building but a different room, and a PT performing a treatment visit via Facetime or Skype in the same building but a different room.

APTA asked if the evaluation and treatment would be considered to have been done in person and thus be billable to Medicare; and whether, if the same approach is taken in a skilled nursing facility, the minutes could be coded on the minimum data set.

CMS' response:

"Both of these instances you mention, where a PT performs an evaluation or treatment visit via Facetime or Skype when in the same building but in different locations describe services that can be billed as in-person services."

“While this policy has enormous potential to help ensure continued access to therapists and other health care providers when attempting to limit contact between patients and their health care providers to prevent the spread of the COVID-19 virus, this is the only information we have on this development at the moment," said Kara Gainer, APTA director of regulatory affairs. "We don't know how this might be applied across the many health care settings, including home health. And the CMS response didn't clearly answer our question about coding these minutes in the skilled nursing facility setting."

This is important: The allowance from CMS is not a recognition of PTs as eligible telehealth providers under Medicare. Medicare still doesn’t include PTs among the providers who can provide face-to-face telehealth; and APTA continues to urge CMS to use its authority to issue a blanket waiver to include PTs among the types of providers eligible to furnish telehealth services during the COVID-19 public health emergency.

APTA staff will continue to pursue this information from CMS and provide more information as it becomes available.

Update, April 10, 2020: CMS' position on how to bill services delivered in the same facility but different rooms was recently reiterated in this CMS FAQ resource (see question 9 under the "Medicare Telehealth" header).

Visit APTA's telehealth webpage for regularly updated information and resources.


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