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PTs and PTAs who provide services via telehealth, be aware: The U.S. Centers for Medicare & Medicaid Services has introduced changes to coding that could affect you in April, if not sooner.

The changes have to do with place-of-service, or POS, codes. Specifically, the agency updated its description of POS 2, “telehealth provided other than in patient's home,” and created a new code, POS 10, “telehealth provided in patient's home” to better reflect the realities of telehealth and prepare for the end of the public health emergency, which currently extends through April 16.

Currently, telehealth services rendered by PTs and PTAs, like most telehealth services, are associated with the same POS code as would be used had the service been provided in person (for instance, the outpatient clinic that the patient would’ve visited). The POS 2 and 10 changes announced by CMS became effective on Jan. 1, but Medicare administrative contractors have been told to hold off on processing claims with these codes until April 4. So for now, PTs and PTAs providing telehealth to Medicare beneficiaries can continue coding as they've been doing but should prepare for a change. Current guidance can be found in Chapter 12, Section 190 of the Medicare Claims Processing Manual.

The same timeline may not hold true for commercial payers. In fact, some commercial payers are already advising providers to start using the POS 2 and 10 codes — and at least one payer has indicated that it will decrease payment when either POS 2 or 10 is used.

The changes to the POS codes don’t answer the bigger question of what will happen to the ability of PTs and PTAs to provide services via telehealth after the public health emergency ends. While a few private insurers, including UnitedHealthCare, have committed to extending this ability beyond the PHE, many more have remained silent on what they'll do. APTA is engaging with commercial insurers to make the case for the adoption of permanent telehealth provisions.

At the federal level, CMS maintains that it’s restricted by law from making any permanent changes to its list of providers who can provide services via telehealth. APTA and other organizations are advocating for legislation that would permanently open telehealth to PTs and PTAs under Medicare, and allow for more flexibility in the U.S. Department of Health and Human Services’ ability to make changes.

Questions on the POS code changes? Contact advocacy@apta.org


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