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The May 11 end of the public health emergency doesn't mean the end of allowances for PTs and PTAs to provide services under Medicare via telehealth — or does it? APTA, the American Occupational Therapy Association, and the American Speech-Language-Hearing Association are pressing the U.S. Centers for Medicare & Medicare Services for answers about inconsistencies in rules that would seem to exclude therapists in a range of facility settings from continuing to provide remote care, even as allowances remain in place for those in all other settings.

In a joint letter to CMS, APTA, AOTA, and ASHA highlight what the organizations hope is a regulatory glitch and not an intentional snub: namely, language that seems to indicate that after the PHE ends, telehealth services cannot be reported on the UB04 claim form widely used by facilities including skilled nursing facilities, home health agencies, and hospital-based outpatient departments, or HOPDs. That restriction would effectively put telehealth out of reach for PTs, PTAs, occupational therapists, and speech-language pathologists who work in any setting that relies on the UBO4 for claims.

The letter points out that that restriction seems to be related to the form used and not setting type, since HOPDs that bill using a different form, the 1500, will continue to be able to provide telehealth services.

Further supporting the need for correction, according to the letter, is the fact that the Consolidated Appropriations Act of 2023, which provided for the extension of telehealth allowances through 2024, lists the sites and settings that would be granted extension — and facilities that use the UB04 are on it. "Again, this seems to extend the ability to provide telehealth services by a variety of providers, including facility-based providers, when the services are billed under the fee schedule," the letter states.

"For these institutional providers and the Medicare beneficiaries they serve, removal of telehealth flexibilities may be inappropriate and, without effective communication, will create significant access-to-care and quality-of-care concerns," the organizations write. "Ultimately, this policy creates significant risk for reduced beneficiary access to medically necessary therapy services, especially in rural and underserved areas." The joint letter was also covered in Inside Health Policy's "Inside Telehealth" news.

The mix-up around the UB04 isn't the only post-PHE detail left unresolved: CMS still needs to reconcile its rule that telehealth waivers would end 151 days after the conclusion of the PHE with the 2023 appropriations act that grants the waivers until Dec. 31, 2024. The agency has signaled that it will bring its rules in line with the legislation when it releases its proposed 2024 Medicare Physician Fee Schedule, expected in July. Until then, APTA advises all PTs and PTAs to pay close attention to CMS and will keep members informed of any developments.

What do PTs and PTAs need to know about the post-PHE landscape? This recent article from APTA, "The End of the Public Health Emergency: What You Need to Know," helps you navigate the changes. Also available: a 17-minute APTA podcast on the same topic.


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