UPDATE: As of April 30, 2020, CMS has authorized PTs, OTs, and SLPs as telehealth providers for the duration of the COVID-19 public health emergency. Learn more in this blog post.
As the reality of pandemic sets in, industries across the country are experiencing a significant dropoff in business—and private practice rehab therapy is no different. Many therapy business owners have reached out to us for recommendations on how to address this, with several requesting information on the telehealth opportunities specifically available to them and their patients.
Unfortunately, while telehealth—that is, conducting patient visits virtually via secure video calls—seems like a simple solution, for rehab therapy providers, it is anything but. That’s because physical, occupational, and speech therapists are not widely recognized as approved telehealth providers for billing purposes. As such, it has largely been used as a supplemental, cash-based service in a very select set of circumstances. Still, therapists want to know exactly how they might go about implementing it—or expanding its use—in their clinics. To that end, here are the facts:
Despite recent CMS action on this front, Medicare still does not recognize rehab therapists as authorized providers of telehealth—and thus, will not reimburse for outpatient rehab therapy services delivered via telehealth.
As of March 16, 2020, there is no explicit policy guaranteeing that Medicare will reimburse PTs, OTs, or SLPs for telehealth or remote monitoring services. As the APTA states in this article, “Physical therapists are not statutorily authorized Medicare providers of telehealth, and physical therapy services delivered via telehealth are not payable under the physician fee schedule. Before you consider furnishing telehealth services to Medicare beneficiaries and collecting out of pocket payment, contact your Medicare Administrative Contractor or CMS regional office to ask for an opinion.”
Commercial payers vary widely in their rehab-specific telehealth policies.
For patients with commercial insurance, we recommend contacting the payer to determine whether the patient has coverage specifically for PT, OT, or SLP telehealth services. Furthermore, per the APTA, “Be sure to confirm with each payer whether the originating site can be a private home or office, if services must be real-time or can be asynchronous, and any other limitations to your use of telehealth.” It also may be useful to review the fee schedule in order to understand which codes are billable and what their reimbursement amounts are. If telehealth is a noncovered service, the practice and the patient may agree to have the patient pay directly for the services. It’s important to note that if a payer denotes a particular billed service “not medically necessary” or “not effective,” the payer will typically assign the balance to the provider, and the practice cannot bill the patient for that service. For more detailed information on telehealth billing, check out this blog post.
State law also affects how rehab therapists can use telehealth.
Additionally, we strongly recommend verifying that telehealth is included in the scope of practice for your state and that telehealth delivery is permitted under all other applicable state laws or regulations. Therapists typically must be licensed in the state in which the patient is receiving services, and while the APTA reports that recent Medicare actions “did include temporarily waiving Medicare and Medicaid requirements that out-of-state providers hold licenses in the state where they are providing services,” we strongly advise exercising caution and conferring with a legal expert before providing any services on an out-of-state basis.
There’s never been a better time to advocate for policy changes that will support rehab therapists’ ability to leverage telehealth.
We’re seeing a strong push for advocacy on the rehab therapy telehealth front. Want to get involved? Check out this recent blog post from Heidi Jannenga, WebPT Co-founder and Chief Clinical Officer, to learn how.