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CMS has waived certain Medicare restrictions on digital communication in light of the COVID-19 pandemic, including "virtual check-in."

A virtual check-in is described as brief communication technology-based services, and the HCPCS code for the service, G2012, is meant to account for the resources involved when you directly furnish the virtual check-in.

The code allows audio-only real-time telephone interactions in addition to synchronous, two-way audio interactions that are enhanced with video or other kinds of data transmission. It requires direct interaction between you and the patient. CMS expects this service to be initiated by the patient.

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 acts and any other applicable state or local laws, which generally require the PT to have evaluated a patient before providing any recommendations or care.

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