More details emerged about CMS guidance on a way for hospital outpatient department PTs and PTAs to provide remote care delivery to Medicare beneficiaries.
In early May, PT in Motion News reported about CMS guidance on a way for hospital outpatient department PTs and PTAs to provide remote care delivery to Medicare beneficiaries. More details have surfaced since then.
The original story is still worth a read, because it lays out the basics of how hospitals can use a patient's address as a "temporary expansion location." But since publication, additional information has come to light:
If the department is "non-excepted."
The CMS interim final rule doesn't change the status of any non-excepted off-campus departments — they are still considered to be non-excepted during the COVID-19 public health emergency, even if they relocate. That means these non-excepted departments will continue to be paid the physician fee schedule rate. It also means they don't need to apply for the relocation approval outlined in the earlier PT in Motion News story.
If the department is "excepted."
It doesn't matter whether the provider-based department — referred to as the PBD — is on or off campus: As long as the department is excepted, hospitals that opt to establish temporary expansion locations need to notify the relevant CMS Regional Office as outlined in the earlier PT in Motion News story.
However, here's what CMS recently indicated during conference calls on May 19 and May 21: If the hospital outpatient department intends to bill for services under the hospital's outpatient prospective payment system, it must follow the guidance for establishing temporary expansion locations. If the only services that the department bills are paid under the physician fee schedule, such as PT, OT, and SLP furnished under a therapy plan of care, then the relocation process doesn't have to be followed.
PO or PN modifier?
Another question APTA has received recently is whether the PO or PN modifier is required on the hospital claim for therapy services furnished remotely but billed as if in person.
The PO modifier is reported with every HCPCS code for all outpatient hospital items and services furnished in an excepted off-campus PBD of a hospital. CMS requires non-excepted off-campus provider-based departments of a hospital to report the PN modifier on each claim line with a HCPCS code for non-excepted items and services. The use of modifier PN will trigger a payment rate under the physician fee schedule. CMS expects the PN modifier to be reported with each non-excepted line item and service, including those for which payment will not be adjusted, such as therapy services.
Bottom line: If your excepted or non-excepted off-campus hospital PBD was billing with the applicable modifier before the COVID-19 health emergency, the off-campus PBD continues to bill with the same modifier, whether or not the services are furnished in person or remotely. Hospital outpatient therapy services furnished under a therapy plan of care will continue to be reimbursed under the physician fee schedule.
In addition to adding the GP modifier when care is furnished by PTs and PTAs under a physical therapy plan of care, hospitals must use the DR condition code and CR modifier. Because the allowances are part of an official response to the public health emergency, both the "Disaster-Related" condition code and the "Catastrophe/Disaster-Related" modifier are required on claims. Details are available in this CMS guidance document.
APTA also continues to advocate for the recognition of hospital outpatient departments and other facility-based providers as eligible providers that can furnish and bill for services furnished via telehealth under the physician fee schedule. Add your voice by visiting APTA's regulatory take-action webpage and using APTA's unique template letter to comment on the COVID-19 public health emergency interim final rule.