The change is happening, albeit incrementally. 

New guidance issued by CMS now allows PTs and PTAs in private practice to make full use of telehealth with their patients under Medicare Part B. Previously, only limited e-visits and other “communication technology-based services” were allowed; the change now includes PTs among the health care providers permitted to bill for real-time face-to-face services using telehealth. This policy change follows a robust advocacy campaign by APTA members and staff.

Aside from telehealth, the revised guidance and accompanying interim final rule contain other provisions relevant to PTs and PTAs. APTA will share these details in subsequent articles. Also, there are multiple details of the telehealth and other provisions that haven't been fully explained by CMS. APTA is working to find answers that fill in the gaps.

The Basics

• Physical therapists in private practice are eligible to bill Medicare for certain services provided via telehealth.
• Services that started as of March 1, 2020, and are provided for the duration of the public health emergency are eligible.
• These CPT codes are eligible to be billed: 97161- 97164, 97110, 97112, 97116, 97150, 97530, 97535, 97542, 97750, 97755, 97760, and 97761.
• Patients may be either new or established.
• These visits are for the same services as would be provided during an in-person visit and are paid at the same rate.
• Patients may be located in any geographic area (not just those designated as rural), and in any health care facility or in their home.

Here are the codes you can use.

These codes are eligible to physical therapists to furnish and bill under the Medicare Physician Fee Schedule when provided via telehealth:

ICPT codes 97161- 97164, 97110, 97112, 97116, 97150, 97530, 97535, 97542, 97750, 97755, 97760, and 97761. See the full list of codes eligible to be furnished and billed via telehealth under Medicare.

When billing claims for telehealth services provided on or after March 1, 2020, and for the duration of the public health emergency, bill with:

• IPlace of Service code equal to what it would have been had you furnished the service in person;
• IModifier 95, indicating that you did indeed perform the service via telehealth; and
• IThe GP modifier.

APTA is seeking clarification from CMS regarding institutional billing of telehealth services.

You will be reimbursed as if the service was delivered in person, and you can find rates for codes being reimbursed under the Medicare Physician Fee Schedule via telehealth using the APTA MPPR Fee Schedule Calculator or CMS Physician Fee Schedule Look-Up Tool.

You can provide services from your home.

During this public health emergency, CMS is allowing PTs in private practice (as well as other providers) to furnish telehealth services from their homes without reporting their home address on their Medicare enrollment while continuing to bill from their currently enrolled location.

There are technology requirements. Follow them.

Services on the Medicare telehealth services list must be furnished using, at a minimum, audio and video equipment permitting two-way, real-time interactive communication between you and your patient.

What if two-way audio and video technology isn't available? CMS acknowledges that there are circumstances where prolonged audio-only communication between you and the patient could be clinically appropriate yet not fully replace a face-to-face visit. In these cases, it's important to remember that during the public health emergency Medicare pays separately for audio-only telephone assessment and management services described by CPT codes 98966-98968. This APTA quick guide can help you learn more about telephone assessment and management services.

Documentation matters. A lot.

Keep in mind the documentation needed to have a proper compliant telehealth program. For more information, view APTA's documentation resources. Also be sure to document the type of technology you used for the evaluation or treatment. For information about obtaining and documenting informed consent, and policies and procedures that you should have in place before furnishing telehealth, visit APTA’s implementing telehealth in your practice webpage.

What about HIPAA?

During this health crisis, the HHS office for Civil Rights is relaxing enforcement and waiving penalties for HIPAA violations against clinicians who in good faith use everyday applications that allow for video chats, such as Apple FaceTime and Skype. But keep in mind: HHS, the Office of the Inspector General, and the Department of Justice will monitor for health care fraud and abuse, including potential Medicare coronavirus scams.

Another important point: You must adhere to any state laws governing privacy and security of patient data.

For additional privacy protections while using video-based telehealth, consider providing services through technology vendors that offer HIPAA business associate agreements with their video communication products. APTA’s Health Policy and Administration hosts a list of rehabilitation telehealth vendors.

Beneficiary cost sharing? Up to you (but waivers won't be covered by Medicare).

Nothing in the guidance or interim rule requires you to reduce or waive copays or other cost-sharing that a Medicare beneficiary may owe for telehealth services during the health crisis, but you will not be subject to administrative sanctions if you do. This applies to face-to-face telehealth services as well as to non-face-to-face services furnished through modalities such as virtual check-ins and e-visits. However, keep in mind that Medicare will not cover the cost of any waived cost sharing.