CMS has waived certain Medicare restrictions on digital communication in light of the COVID-19 pandemic, including "telephone assessment and management services."

Telephone assessment and management services are services you provide to an established patient, parent, or guardian via real-time phone conversation, and are initiated by the patient. The services are billed using CPT codes 98966, 98967, and 98968.

Although the code descriptor refers to an established patient that you currently are treating under a plan of care, CMS says it is "exercising enforcement discretion" on an interim basis and will not conduct reviews to consider whether these services were furnished to established patients. However, APTA advises you to continue to comply with your state practice act and any other applicable state or local laws, which generally require the PT to have evaluated a patient before providing any recommendations or care.