Blog Post

Where Does Telehealth Go From Here?

Rehab therapists must walk a long road toward permanent telehealth privileges.

Melissa Hughes
5 min read
December 14, 2021
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Back before the days of personal cell phones and robotic voices that hummed directions from a GPS device, roadtrippers of all stripes relied on maps and road signs to direct them across the windy thoroughfares that connected towns and cities—and the country at large. Without a map or intimate knowledge of the region, it was near impossible to get where you were going—unless you flagged down a local.

And while the nature of road tripping has changed forever (and you’re much less likely to get lost in a new city), the principles of having a map apply in other areas of life. You need to know where you’re going in order to make plans.

And that’s where this extended metaphor is going: In order to plan and effectively advocate for professional growth and industry evolution, rehab therapists need a map. Rehab therapists need to know where the heck telehealth is going—or where it could go from here.

The Roads Telehealth Took to Get Here 

Prior to the pandemic, telehealth wasn’t very popular—at least not with rehab therapists. And that was largely due to how complicated it was; Medicare, Medicaid, and commercial payers varied wildly on their telehealth policies—and whether rehab therapists could even legally provide telehealth in their state was a total coin toss. Some state practice acts expressly forbid it, while others forbid it in some circumstances, and others still allow it. 

The COVID-19 pandemic, of course, flipped telehealth on its head. Suddenly, with stay-at-home orders and widespread unease about meeting in person, everyone was clamoring to provide remote care to patients—including rehab therapists. Over time, CMS released emergency orders, allowing many different providers to furnish (and be paid for) telehealth for the first time—and on April 30, 2020, PTs, OTs, and SLPs were added to this list. 

Following suit, many states temporarily amended their state practice acts, letting new providers (including rehab therapists) furnish telehealth for the first time—which brings us to where we are today. 

Telehealth’s Current Location

So, you may be asking, “Where is telehealth at right now?” Plainly speaking, telehealth is in limbo. On one hand, many providers have finally gotten their feet wet and tested out the world of digital care, often finding that telehealth is an excellent tool that helps patients and expands access to care. (People like it, basically.) But on the other hand, the temporary mandates that let clinicians—especially rehab therapists—provide telehealth are just that: temporary. 

Once the federal government officially declares an end to the public health emergency caused by COVID-19, telehealth legislation will (for the most part) revert to the way it was back in 2019. In other words, PTs, OTs, and SLPs will no longer be paid by Medicare for telehealth—and many states will revoke the few telehealth privileges they doled out during the past couple years.

Because of the current state of the legislation, telehealth is on the brink of losing its viability as a treatment option. If action is not taken to revise this legislation so that telehealth can continue beyond the pandemic, rehab therapists will not be able to provide synchronous virtual care to many patients who need it—potentially for a very long time.    

Telehealth’s Future Destination 

While it’s not ideal that telehealth is hanging out in limbo, it means that its immediate future is more pliable than ever. Rehab therapists have a choice: They can choose to let it be, and accept that their pandemic-spawned telehealth privileges will quietly fade away—or they can take dedicated, specific action to make telehealth a permanent fixture of rehab therapy care.

Here’s what that action must look like: 

Get congress to allow PTs, OTs, and SLPs to provide telehealth.

I know, I know. This is a pretty hefty “first step” to securing permanent telehealth privileges—but it’s a necessary one. As it stands, the Centers for Medicare and Medicaid Services (CMS) do not have the legal ability to give rehab therapists permanent telehealth privileges. This is because rehab therapists are not on CMS’s list of eligible telehealth providers.

Turns out, only an act of Congress can change that list, which is why PTs, OTs, and SLPs need buy-in from congressional leaders in order to provide synchronous remote healthcare beyond the pandemic. The good news here is that professional advocates are already on the case. 

Here’s what you can do. 

Due to the advocacy efforts of organizations like the APTA, APTQI, AOTA, and ASHA, the Expanded Telehealth Access Act (H.R. 2168) is making the rounds through Congress. If this is an act that you’re interested in supporting, reach out to your local congressional representative and voice your approval for this bill. Whether you send a templated letter or make a quick five-minute phone call, your voice can add to this movement.  


Prove to CMS that teletherapy is effective and beneficial to patients. 

Once rehab therapists officially become eligible telehealth providers, the ball is back in CMS’s court. Currently, CMS is of the mind that therapy services should not be provided digitally once the pandemic is over. (Seriously, take a gander at the 2022 final rule for proof.) Specifically, CMS said in the 2022 proposed rule that, “we concluded that it did not provide sufficient detail to determine whether all of the necessary elements of the service could be furnished remotely, and whether the objective functional outcomes of ADL and IADL for the telehealth patients were similar to those of patients receiving the services in person.”

But CMS also left the door open for PTs, OTs, and SLPs, offering them a chance to secure telehealth privileges if they could supply data proving its outcomes and efficiency. “We continue to encourage commenters to supply sufficient data for us to be able to see all measurements/parameters performed, so that we may evaluate all outcomes.”

Here’s what you can do. 

If you want to help speed along this piece of telehealth advocacy, begin collecting telehealth data. PTs, OTs, and SLPs have a small (and rapidly shrinking) window of time to provide teletherapy to their Medicare patients and collect data about it. If ever there was a time to roll up your sleeves and conduct a study on your patients, this would be it. 

If you do decide to collect some data for this, determine if the patients who receive telehealth are progressing at the same rate, faster, or slower than your other patients. Track their outcomes—see if you can reasonably demonstrate that outcomes are not affected (or maybe even improve) when telehealth enters the equation. Just be sure not to overly reference ADLs, as CMS has said, “We do not believe ADLs and IADLS alone are sufficient to demonstrate clinical benefit to a Medicare beneficiary.”

Finally, the next time the proposed rule rolls around (usually sometime late-summer), submit that data to CMS via the comment portal. 

Advocate for individual state legislation that permanently includes telehealth privileges in therapists' state practice acts.

Alright, hypothetically speaking, let’s say that Congress has officially deemed rehab therapists eligible healthcare providers, and the Medicare program officially pays for remote rehab therapy services. That’s half the journey done, right there! Many payers mimic CMS’s Medicare rulings, meaning those wins are likely to set off a domino effect in commercial payer rulings and regulations. 

That said, there’s one stretch to push through in the fight for permanent telehealth advocacy: Rehab therapists must advocate for individual state legislation that permanently includes telehealth privileges in therapists' state practice acts.

Remember at the beginning of the article when I mentioned that state practice acts are all over the place when it comes to telehealth? Well, that’s what PTs, OTs, and SLPs are up against. Even after winning federal telehealth support, y’all must win state support in order to furnish remote care. 

Here’s what you can do. 

As you might imagine, state-level legislative changes must be advocated by state organizations. That means the national APTA, AOTA, or ASHA organizations won’t necessarily be well-equipped to go toe-to-toe with your governor. In order to clear this final telehealth hurdle, PTs, OTs, and SLPs will need to work with their state chapter of one of these professional organizations. That’ll take a little legwork; you’ll have to look up your local chapter (assuming you’re not a part of it), reach out, and maybe even do a little more work than you would advocating at the federal level. 

The returns for advocating at the state level, though, are often great. States have a ton of rights, and can make significant rulings over their jurisdiction. 

When it comes to securing telehealth privileges, rehab therapists have a long road ahead of them with very specific mile markers to pass. But, with a map of the road and a plan to follow, PTs, OTs, and SLPs will make it to their final destination, telehealth privileges in hand. 

Download your free telehealth advocacy template.

Enter your email below, and we’ll send you a free letter template you can use to lobby CMS to add PTs, OTs, and SLPs to the list of authorized telehealth providers.


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