Resource and Payment Updates from the WPTA
APTA COVID-19 E-visit Quick Reference - http://www.apta.org/COVID-19/E-Visit/QuickReference/
APTA Telehealth FAQs - http://www.apta.org/PTinMotion/News/2020/03/18/E-VisitFAQs/
Acute Care Resources - https://www.acutept.org/page/COVID19
APTA Private Practice Section offers Many Resources for all to Use - https://ppsapta.org/physical-therapy-covid-19.cfm#
Special Edition of Impact Magazine on COVID-19 - https://lsc-pagepro.mydigitalpublication.com/publication/?i=655319
Important Information for Early Intervention Providers: - https://www2.ed.gov/policy/speced/guid/idea/memosdcltrs/qa-covid-19-03-12-2020.pdf?utm_content=&utm_medium=email&utm_name=&utm_source=govdelivery&utm_term=
Guidance for Home Health Providers - https://aptahhs.memberclicks.net/coronavirus--information-for-providers
Telehealth Billing Information:
For a list of current telehealth billing guidelines as of March 27, click here.
New Medicare Telehealth Billing Opportunities for the COVID-19 Response
As of March 17, 2020, CMS has relaxed its telehealth requirements in response to COVID-19. Per these updates, Medicare will reimburse PTs, OTs, and SLPs for certain telehealth services—as noted by the code list below—that occurred on March 6 or later.
Updated Coverage of Rehab Therapy Telehealth
As per CMS’s latest update, PTs, OTs, and SLPs can bill Medicare (and receive payment) for the following telehealth services:
• 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.”
It’s important to note, though, that these codes apply exclusively to what CMS calls “E-Visits.” According to the fact sheet for this update, “These services can only be reported when the billing practice has an established relationship with the patient. For these E-Visits, the patient must generate the initial inquiry and communications can occur over a 7-day period.”
Per CMS, “E-Visits” differ from “Telehealth Visits,” which encompass any “office, hospital visits and other services that generally occur in-person.” PTs, OTs, and SLPs still are not included in the list of providers who are eligible to conduct Telehealth Visits under Medicare.
As the fact sheet states, “Distant site practitioners who can furnish and get payment for covered telehealth services (subject to state law) can include physicians, nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologists, clinical social workers, registered dietitians, and nutrition professionals.”
Here are some other key things to know about E-Visits per the waiver release:
• “These services can only be reported when the billing practice has an established relationship with the patient.
• This is not limited to only rural settings. There are no geographic or location restrictions for these visits.
• Patients communicate with their doctors without going to the doctor’s office by using online patient portals.
• Individual services need to be initiated by the patient; however, practitioners may educate beneficiaries on the availability of the service prior to patient initiation.
• The services may be billed using CPT codes 99421-99423 and HCPCS codes G2061-G2063, as applicable.
• The Medicare coinsurance and deductible would generally apply to these services.”
Additionally, when billing Medicare for E-Visits during the COVID-19 response period, rehab therapists should use the POS 11 or 12 (indicating they are located in an office or a home, respectively) as well as the CR modifier (indicating the services are catastrophe/disaster related)—not the 95 modifier.
HHS Office for Civil Rights (OCR) will waive HIPAA violation penalties against providers who offer “good faith” services to patients through everyday communication technologies (e.g., Skype or Facetime).
Non-Coverage of Rehab Therapy Telehealth and Patient Cash-Pay
As with all medically necessary services, third-party payer coverage is only part of the patient’s decision process. Consider dry needling: noncoverage in that case creates an opportunity to discuss the benefits of the service.
If a service is not covered by a payer for which you are a preferred provider, you may collect payment directly from patients at the time of service. However, before you do this, create a fee schedule for your telehealth services, and create a transparent billing process for your patients. Notify these patients (in writing) that telehealth services are not covered by their payer, and clearly establish the projected cost as well as when you expect payment. If you are not a preferred provider, you are not bound by their noncoverage of your services.
Modifier 95, when applied, designates that the services were delivered synchronously in real-time using a HIPAA-compliant program. The modifier is available for use with the new codes made available to rehab therapists as part of the COVID-19 response.
Modifier GT, when applied, designates that the services were delivered synchronously in real-time using a HIPAA-compliant program. GT is the modifier that is most commonly used for telehealth claims. Per the AMA, the modifier means “via interactive audio and video telecommunications systems.” You can append GT to any CPT code for services that were provided via telemedicine
Modifier GQ, when applied, designates that the services were delivered asynchronously using a HIPAA-compliant program. This is considered an “old” modifier and method of delivering telehealth, and it’s slowly getting replaced by synchronous technologies.
The CR modifier—which indicates that services are catastrophe/disaster-related—is mandatory when billing Medicare using the CPT codes for COVID-19-related E-Visits, which were recently made available to rehab therapists. (These codes are defined in the “Updated Coverage of Rehab Therapy Telehealth” subsection below.) This modifier is reserved for claims for which Medicare Part B payment is conditioned directly or indirectly on presence of a “formal waiver” like the one issued in response to COVID-19. It should be used for qualifying Part B items and services related to both institutional and non-institutional billing.