On Thursday, April 30, the Centers for Medicare and Medicaid Services officially made physical therapists, occupational therapists, and speech-language pathologists eligible to deliver—and receive reimbursement for—telehealth services for the remainder of the public health emergency period. This change—along with all other temporary provisions included in the full CMS bulletin—is retroactive to March 1, 2020.
According to this CMS news release, “For the duration of the COVID-19 emergency, CMS is waiving limitations on the types of clinical practitioners that can furnish Medicare telehealth services. Prior to this change, only doctors, nurse practitioners, physician assistants, and certain others could deliver telehealth services. Now, other practitioners are able to provide telehealth services, including physical therapists, occupational therapists, and speech language pathologists.”
This means Medicare—like many commercial payers—will now reimburse rehab therapists for regular therapy services (i.e., those billed using 97000-series CPT codes) delivered via telehealth. According to a previous CMS announcement, covered codes include:
- Initial evaluations and re-evaluations (97161–97168)
- Therapeutic exercise (97110)
- Neuromuscular re-education (97112)
- Gait training (97116)
- Self-care/home management training (97535)
- Physical performance test or measurement (97750)
- Assistive technology assessment (97755)
- Orthotics management and training (97760)
- Prosthetic training, upper and/or lower extremities, initial prosthetic encounter (97761)
- Speech/language evaluations (92521–92524)
- Speech/language treatment (92507)
The bulletin also notes that CMS will allow PTs and OTs to delegate maintenance therapy services to physical therapist assistants (PTAs) and occupational therapy assistants (OTAs) in outpatient settings, thus allowing therapists to focus on “other important services and improve beneficiary access.”
According to this APTA news release, rehab therapists should add the following to claims for telehealth services for the duration of the public health emergency:
- The same place of service (POS) code that would apply if the service had been furnished in person;
- Modifier 95, which indicates the service was furnished via telehealth; and
- The applicable therapy modifier (e.g., GP, GO, or GN).
Additionally, hospital-based practitioners can provide—and hospitals may bill for—telehealth services for Medicare patients who are registered as hospital outpatients (this includes patients who are at home “when the home is serving as a temporary provider based department of the hospital”). When hospital-based practitioners deliver telehealth services to Medicare patients who are registered as hospital outpatients, hospitals may bill as the originating site. That being said, according to this APTA bulletin, this “shouldn’t be interpreted as a green light for hospital-based PTs and PTAs to engage in remote therapy.” That’s because “the hospital first must register the patient’s home as a temporary expansion location of the hospital’s outpatient department, referred to as the provider-based department or PBD, during the public health emergency. Registration includes justifying the need to add a relocation site such as a patient’s home.” Refer to the full APTA bulletin for more information.
APTA also confirms here that physical therapist assistants (PTAs) and occupational therapy assistants (OTAs) are eligible to provide telehealth services as long as the level of supervision meets existing Medicare guidelines. While CMS has indicated that, as noted here, virtual direct supervision “may be allowed under certain circumstances,” the APTA cautions therapy providers against leveraging virtual supervision of assistants until CMS confirms in writing that this is permissible.
CMS has also indicated it will allow many telehealth services to be delivered in an audio-only (i.e., telephone) format, even though those services typically require practitioners to use a secure, two-way video connection. However, it is not clear how this allowance applies to rehab therapists, as the codes CMS instructs providers to use for audio-only telehealth (99441–99443) are not typically used by PTs, OTs, and SLPs.
As noted in the full bulletin, “CMS is waiving the requirements…for use of interactive telecommunications systems to furnish telehealth services, to the extent they require use of video technology, for certain services.” Furthermore, as noted here, “When clinicians are furnishing an evaluation and management (E/M) service that would otherwise be reported as an in-person or telehealth visit, using audio-only technology, practitioners may bill using these telephone E/M codes provided that it is appropriate to furnish the service using audio-only technology and all of the required elements in the applicable telephone E/M code (99441-99443) description are met.” The news release also states, “CMS is also increasing payments for these telephone visits to match payments for similar office and outpatient visits.” For the time being, until CMS provides further clarification, rehab therapists may bill for audio-only services using the telephone visit codes CMS previously made available to PTs, OTs, and SLPs (i.e., 98966–98968). However, it is not clear whether the reimbursement provisions that apply to the telephone E/M codes also apply to the telephone visit codes.
Check out the full bulletin for a summary of all temporary measures CMS has implemented to support patients and providers during the COVID-19 pandemic. We’ll update this post as more details emerge.