As we reported here, as of March 17, 2020, CMS will reimburse PTs, OTs, and SLPs for certain telehealth services provided during the COVID-19 response. Specifically, these provisions apply to services that occurred on or after March 6, 2020.
Previously, Medicare did not reimburse rehab therapists for any virtual services, as PTs, OTs, and SLPs have never been—and still are not—included on Medicare’s list of approved telehealth providers. And Medicare still does not cover rehab therapy telehealth to the same extent that it covers telehealth services delivered by other provider types.
That being said, in a select set of circumstances, rehab therapists may now bill Medicare for what it calls “e-visits.” Please note that these are not new codes. They have been around for a while, but this is the first time rehab therapists have been eligible to bill them.
The codes for these e-visits are as follows, according to this CMS fact sheet:
- G2061: Qualified non-physician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the 7 days; 5–10 minutes
- G2062: Qualified non-physician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 11–20 minutes
- G2063: Qualified non-physician qualified healthcare professional assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 21 or more minutes.
Now, because billing Medicare for any type of virtual care is a brand-new thing for rehab therapists, you probably have a lot of questions about it. In fact, we know you do, because we’ve been inundated with inquiries in virtually all public- and customer-facing channels. To help you sort it all out, here are our answers to some of the most frequently asked questions we have received.
What, exactly, is an e-visit—and how is it different from other types of telehealth?
In its most recent physician fee schedule final rule, CMS describes an e-visit as “non-face-to face…patient-initiated digital communications that require a clinical decision that otherwise typically would have been provided in the office.” As indicated by the code descriptors, these codes are not intended for use to bill any treatment or service provided via a telehealth channel or platform. Instead, they are meant to be used for assessment and management purposes after a patient has been seen for regular treatment. As explained in this APTA resource, “the codes are intended to cover short-term (up to seven days) assessments and management activities that are conducted online or via some other digital platform and include any associated clinical decision-making.”
What constitutes “assessment and management” for the purposes of these codes?
You could apply toward the billable time for these codes any minutes spent not only interacting with the patient—that is, writing messages or speaking in real-time via phone or live video conferencing—but also gathering information and using your clinical decision-making abilities to distill it into guidance for the patient. For example, the patient may reach out with concerns about developing symptoms or questions about his or her home exercises—and you may need to conduct further research in order to provide the patient with the best possible answer. You would bill for the cumulative time you spent on these activities over the course of the seven-day period covered by the code. Therapists should not think of these e-visits as therapy sessions, but rather as time spent assessing and managing (i.e., using clinical decision-making to update plans and provide guidance) outside of normal treatment sessions for the purpose of helping the patient maintain or progress function.
What kind of platform must I use in order to conduct and bill for e-visits?
Per CMS, these e-visits should be conducted via “online patient portals.” This APTA resource defines an online patient portal as “a secure online website that gives patients convenient, 24-hour access to personal health information from anywhere with an internet connection. A patient portal requires a secure username and password to allow patients to securely message their provider.” While we always recommend using a secure, HIPAA-compliant platform that will enter into a business associate agreement (BAA), per this announcement from the Office for Civil Rights (OCR) at the Department of Health and Human Services (HHS), providers who use other, more popular and accessible platforms for the purposes of telehealth during the COVID-19 response will not be subject to HIPAA penalties. According to a recent APTA webinar, this includes using the telephone, email, and familiar consumer applications like Facetime and Skype. That being said, you should avoid using any platform that may release communications to the public.
Can I bill these e-visit codes for any other insurances?
While these provisions are Medicare-specific, other payers may follow suit. Check with your individual payers to determine:
- whether they are covering rehab therapy telehealth as part of the COVID-19 reponse,
- what types of services they are covering,
- what, if any, special requirements or stipulations apply, and
- which CPT codes and modifiers you should use to bill for those services.
The APTA is working closely with major commercial payers—including BCBS, Cigna, and UnitedHealthcare—to expedite their adoption of temporary guidelines for rehab therapy telehealth. Please note that many Medicare Advantage plans are offered by these major commercial payers and thus, are subject to their guidelines as well. Aetna has announced that it will open the e-visit codes to rehab therapists (similar to Medicare) in addition to implementing a few other telerehab expansions. Tricare announced the adoption of similar guidelines.
Keep in mind that some commercial and workers’ compensation payers may require the use of CPT codes rather than HCPCS codes, and G2061–G2063 are HCPCS codes. The CPT equivalents of these codes are 98970–98972. So, when you ask other insurances whether they are allowing rehab therapists to bill for e-visits, make sure you confirm which code set the payer uses for those visits.
Please note that Medicaid policy is determined at the state level. Thus, to determine whether your state’s Medicaid program covers e-visits or any other form of telehealth, please contact your state board or state APTA chapter, AOTA state association, or ASHA state association. If you find that your state does not allow for the provision of any rehab therapy telehealth services, consider taking this opportunity to advocate for change. The more change happens at the state level, the more likely we are to see meaningful change at the national level.
Can I bill these e-visit codes for any Medicare patient?
No. You should not bill these codes:
- if you do not have an established relationship with the patient,
- more than once during a seven-day period, or
- if the encounter was not patient-initiated.
What does it mean to have an established relationship with a patient?
The APTA recommends consulting your state practice act to see how it defines “established patient.” Generally speaking, these codes are available only for patients who are currently under the care of the billing provider.
If a patient’s plan of care has expired or the patient was discharged, is that patient eligible for e-visits?
The APTA is seeking clarification on this, as CMS has not provided exact guidelines for discharged or inactive patients. However, during a recent town hall discussion, APTA reps indicated they are hopeful that e-visit provisions would extend to past patients.
Is it a problem that e-visits weren’t included in the patient’s certified plan of care?
No. E-visits function as an exception to the plan of care. There’s no need to re-evaluate the patient or recertify the plan of care simply to add these services to the patient’s plan.
Why does the service have to be patient-initiated—and how does Medicare define “patient-initiated?”
The patient must be the one to reach out and seek the service. While the provider can notify established patients of their ability to initiate e-visits—via an email or an announcement on the provider’s website or social media pages, for example—the patient must actually initiate the visit. This prevents providers from delivering and billing for unnecessary services.
Do I need to obtain the patient’s consent before providing an e-visit service?
Yes. Because you intend to bill for these services, you are required to obtain the patient’s verbal consent. Simply ask the patient if he or she is willing to participate in an e-visit before you address the patient’s reason for reaching out to you.
How is the seven-day period calculated?
This period covers seven consecutive days beginning when the provider responds to the patient’s request for an e-visit.
Can I bill more than one e-visit code during the seven-day period?
No. You should select the code that best represents the total amount of time you spent providing this service over the course of seven consecutive days.
Once the seven-day period has ended, can I bill another e-visit code for a new seven-day period?
It is unclear whether providers can bill multiple e-visit codes across multiple seven-day periods throughout a single plan of care. According to this resource, the APTA is seeking clarification from CMS on this matter.
Do I need to use any particular modifiers when billing e-visit codes during the COVID-19 response period?
Yes. You will need to affix modifier CR—which indicates that services are catastrophe or disaster-related—when billing Medicare’s e-visit codes. You should not use any other modifiers in association with these codes.
Which place of service (POS) designation should I use when billing these e-visit codes?
The place of service is the location of the billing practitioner. So, if your location is an office, use POS 11. If your location is the home, use POS 12. According to CMS guidance that the APTA published here, “In the case with remote services, the locality that is assigned to the claim is based on the place where the claims service was rendered. Therefore, in this situation, if the physician/practitioner doing the monitoring is in, for example, Maryland, and the beneficiary is in New York, the locality or POS is Maryland. The issue is ‘where the service was rendered,’ and in the example above, the service was rendered in Maryland, because that’s where the physician/practitioner is located. That would come in on the claim as the place where the service was rendered. It does not matter where the corporate address of the billing provider is, nor does it matter what the beneficiaries’ addresses are. It matters where the service was rendered; that is, where the biller is located.”
How should I document to support billing for these services?
First off, be sure you document that the patient initiated the service. If possible, document how the patient initiated the service. It’s also important to document that the patient consented to receiving e-visit services, because ultimately, you will bill the patient’s insurance (e.g., Medicare) for those services.
Then, clearly document the services provided, just as you would to support billing any other code. Specifically, make sure you document all assessment and management provided across the seven-day period as well as the clinical decision-making associated with that assessment and management. This includes documenting not only the patient interactions themselves, but also the activities you are conducting outside of those interactions—such as researching clinical best practices or consulting with other providers—that contribute to your clinical decision-making and the guidance you ultimately provide the patient. Additionally, document the reason why the patient is unable to attend the visit in person.
We recommend documenting all of these elements as you go (i.e., throughout the seven-day period) in addition to creating a summary of the entire seven-day period. Keep in mind that you will not follow the format you’re used to for a typical therapy note with actual interventions, so try not to use that as a guide. In the event of payer review, you’ll also want to have a record of your use of your telehealth platform, even if that means taking screenshots of session times logged in consumer applications (e.g., Facetime or Skype, per OCR’s aforementioned “good faith” provisions).
What are the fee schedule values for these e-visit codes?
You can use CMS’s physician fee schedule search tool to find information specific to your location. That being said the non-facility national payment amount averages are as follows:
- G2061: $12.27
- G2062: $21.65
- G2063: $33.92
Do Part B Medicare coinsurances and deductibles apply to these codes?
Yes. According to the CMS fact sheet, “The Medicare coinsurance and deductible would generally apply to these services.”
Are the e-visit codes eligible for reimbursement under Medicare Part A?
No. These codes are eligible for Part B reimbursement only. With respect to home health in particular, an e-visit cannot substitute a routine home health visit.
Can PTAs provide and bill for e-visit services?
As of the publication of this FAQ, physical therapist assistants (PTAs) and occupational therapy assistants (OTAs) are believed to be excluded from the list of practitioners who can conduct and bill for e-visits.
Is there an e-visit code for group therapy?
No. If you are providing services to more than one patient at the same time—for example, if you are treating a husband and wife during the same video-conferencing session—you would bill separately for each patient.
Can I provide telehealth services beyond the e-visits to Medicare patients on a cash-pay basis?
Yes, as long as you have an advance beneficiary notice of noncoverage (ABN) on file. Learn more about ABNs here.
How long will these temporary provisions be in effect?
That remains to be seen. We’ll provide updates as the situation progresses and details emerge, so stay tuned to the WebPT Blog.