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The clarification from CMS applies to settings that use institutional claims such as UB-04.

It's settled: Medicare Part B institutional claims for outpatient therapy services furnished through telehealth are permitted for hospitals, skilled nursing facilities, critical-access hospitals, comprehensive outpatient rehab facilities, rehabilitation agencies, and home health agencies. APTA pressed CMS for recognition of institutional settings that provide outpatient therapy for months; CMS' May 27 answer is a clear win for PTs, PTAs, and their patients.

News of the clarification came by way of an update to CMS' lengthy Frequently Asked Questions resource on fee-for-service billing, a document with a particular focus on so-called 1135 waivers that CMS adopted in response to the COVID-19 public health emergency. Those waivers included allowances for telehealth by PTs, occupational therapists, and speech-language pathologists in certain circumstances, but details of exactly who could do what vis a vis remote care have only emerged over time.

The specific answer to the institutional setting question appears near the end of the document (page 70 at the time of this article, but citing a specific page number isn't always helpful as CMS updates the FAQs on a regular basis).

In CMS' own words, "Outpatient therapy services that are furnished via telehealth, and are separately paid and not included as part of a bundled institutional payment, can be reported on institutional claims with the "-95" modifier applied to the service line." The guidance goes on to say that this applies to hospitals for outpatient therapy services (bill type 12X or 13X), SNFs (bill type 22X or 23X), CAHs (bill type 85X), CORFs (bill type 75X), ORFs (rehabilitation agencies) (bill type 74X), and HHAs (bill type 34X).

When use of the waivers were announced in mid-March, it was unclear to what extent remote services would be permitted for PTs and PTAs. Over the following months, CMS clarified its interpretation of the waivers, first by permitting therapy "e-visits," then clarifying that PTs and PTAs in private practices could engage in real-time video telehealth with patients. In early May, the agency acknowledged a pathway for hospital outpatient department PTs and PTAs to furnish remote services under Medicare. However, the ability of institutional settings to bill outpatient therapy furnished via telehealth was not directly addressed — until this week.

"Until now, CMS did not specifically address a major area of care that encompasses a large number of PTs and PTAs, so we're grateful that we were able to help spark these clarifications," said Kara Gainer, APTA director of regulatory affairs. "The answer CMS provided is good news for PTs and PTAs in these settings whose primary concern is to be able to safely deliver effective, high-quality services to Medicare beneficiaries."

The waivers are temporary and will be withdrawn when the public health emergency is officially ended. In the meantime, APTA is advocating to HHS and CMS about the importance of extending the telehealth policy flexibilities after the emergency declaration ends. Supporters can lend their voices to this effort by submitting comments on CMS’ additional policy revisions in response to the COVID-19 public health emergency interim final rule.

In addition, APTA also continues press Congress for permanent telehealth allowances for PTs and PTAs.

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