Therapy Newsletter’s COVID-19 Response Unit

A Financial Relief Plan & Telehealth Guidance to Reduce your Burden and Help Combat COVID-19

Use our financial relief plan to reduce your economic burden, and telehealth guidance plan to maintain business continuity during the COVID-19 pandemic.

An open letter from Therapy Newsletter CEO Nitin Chhoda PT, DPT

“What gets us into trouble is not what we don’t know. It’s what we know for sure that just ain’t so.”

 – Mark Twain

Updated 9.55 am EST on Tuesday, 9-29

Please bookmark this article since it is updated daily

Disclaimer: This resource is updated in real-time, multiple times a day and is informational only. None of the content is legal or billing advice, and every reader is solely responsible for their own actions, and for independently verifying any / all content below including the Telehealth Manifesto resource. All content is protected by US copyright law and reproduction is strictly prohibited without written permission of Therepy Newsletter. Email support@therapynewsletter.com for permissions and questions.

To all private practice owners, physical therapists and members of our community,

COVID-19 has changed life as we know it. The things we felt sure about don’t feel so sure anymore.

This is a moment of reckoning unlike any other in modern times. The extent of destruction will depend on how we monitor the virus, and how we exercise our civic responsibility over the next few weeks.

The White House has called this ‘war’. Some thought leaders have called for a nationwide shutdown and referred to COVID-19 as a ‘once in a century pathogen’.

As private practice owners and clinicians, we are the soldiers at the front lines of this war. Patients, elderly family members and children depend on us for solace and comfort. Ironically, we look after everyone but ourselves, as we risk exposure going to work and getting into close contact with patients.

To help the community, Therapy Newsletter has formed the Therapy Newsletter COVID-19 Response Unit (CRU) to alleviate some of the financial burden and provide emergency guidance on e-visits and telehealth.

Private practice owners are hurting. Patient cancellations, delays with reimbursements and inability to meet payroll are taking place all over the country. Practice owners are scrambling to conduct telehealth and cut costs as quickly as they.

The CRU has prepared this article to give readers accurate, real-time information about everything that must be done during this crisis.

BREAKING NEWS – CMS Now Allows PT / OT / Speech to Get Reimbursed for Telehealth Services

A major new announcement emerged on page 1 of a 36-page report released on the Coronavirus Waivers & Flexibilities page of the CMS website

In this document, entitled “COVID-19 Emergency Declaration Blanket Waivers & Flexibilities for Health Care Providers (PDF) UPDATED (4/30/20)”, CMS stated:

Pursuant to authority granted under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) that broadens the waiver authority under section 1135 of the Social Security Act, the Secretary has authorized additional telehealth waivers. CMS is waiving the requirements of section 1834(m)(4)(E) of the Act and 42 CFR § 410.78 (b)(2) which specify the types of practitioners that may bill for their services when furnished as Medicare telehealth services from the distant site. The waiver of these requirements expands the types of health care professionals that can furnish distant site telehealth services to include all those that are eligible to bill Medicare for their professional services. This allows health care professionals who were previously ineligible to furnish and bill for Medicare telehealth services, including physical therapists, occupational therapists, speech language pathologists, and others, to receive payment for Medicare telehealth services.

Translation – CMS will now reimburse physical therapists, occupational therapists and speech-language pathologists for certain telehealth services. There is a possibility that CMS may cover telehealth services performed by PTA/OTA under the supervision of the PT/OT. The APTA is seeking clarification from CMS about this. Also, no guidance has currently been provided on whether telehealth can be billed out via UB04 claim forms.

CMS is indeed taking aggressive action. CMS states:

CMS is empowered to take proactive steps through 1135 waivers as well as, where applicable, authority granted under section 1812(f) of the Social Security Act (the Act) and rapidly expand the  Administration’s aggressive efforts against COVID-19. As a result, the following blanket waivers are in effect, with a retroactive effective date of March 1, 2020 through the end of the emergency declaration

Translation – PT / OT / Speech therapists who conducted telehealth visits on or after March 1, 2020 will get reimbursed for specific CPT codes furnished via telehealth.

Additional Important Considerations

  1. Medicare pays the same amount for telehealth services as it would if the service were furnished in person. In other words, these visits are for the same services as would be provided during an in-person visit and are paid at the same rate.
  2. A list of all CPT codes services payable under the Medicare Physician Fee Schedule when furnished via telehealth is available here on the CMS website under “list of telehealth services”.
  3. The POS guidance is similar to an in-person visit. This means that the POS would be 11 if the Medicare patient was seen in an outpatient clinic, for example just like an in-person outpatient visit, the GN, GO or GP modifier will need to be applied.
  4. During the PHE, the CPT telehealth modifier (modifier 95) should be applied to claim lines that describe services furnished via telehealth. Practitioners should continue to bill these services using the CMS1500/837P.
  5. Adherence to the state-specific practice act, state / county laws and contractual obligations with all payers is the responsibility of every individual PT, OT and speech therapist.
  6. Patients may be either new or established.
  7. Patients may be located in any geographic area (not just those designated as rural), and in any health care facility or in their home.
  8. Practitioners can render telehealth services from their home without reporting their home address on their Medicare enrolment while continuing to bill from their currently enrolled location.
  9. Remember that the documentation is important for telehealth services. You may want to use an audio-video 2-way communication platform like Skype, FaceTime or Zoom. Document the type of technology used for the evaluation or treatment and document the patient consent. Detailed guidelines about telehealth are available in the telehealth manifesto article.

Specific Examples Of Physical Therapy Telehealth Codes

The In Touch Billing team evaluated the entire list of telehealth services codes and identified several codes that apply to physical therapy. Please note that you will have to unzip the files, and then possibly rename the CSV files in order to open the excel document from CMS.

CPT Description
97161 PT Eval low complex 20 min
97162 PT Eval mod complex 30 min
97163 PT Eval high complex 45 min
97530 Therapeutic activities
97110 Therapeutic exercises
97112 Neuromuscular reeducation
97116 Gait training therapy
97164 PT re-evalest plan care
97535 Self-care management training
97750 Physical Performance Test
97150 Group therapeutic procedures
97542 Wheelchair management training
97755 Assistive Technology Assess
97760 Orthotic mgmt. &traing 1st en
97761 Prosthetic traing 1st enc

Translation – CMS will pay “full price” to PT / OT and Speech for approved telehealth codes and the entire list of codes is available here on the CMS website.

Click here for the CMS webpage to keep track of all waivers and liabilities related to coronavirus

If you are an Therapy Newsletter customer, schedule a call with a member of our management team using this link. Together, we will explore options to ease your financial burden.

If you are not a customer yet, contact customer support and ask about scholarships, service fee waivers, 90 day payment deferments and more. We’ll find the best plan for you to maintain patient communication and business continuity. The following services are eligible:

In Touch EMR and In Touch Biller Pro – Integrated Scheduling, Documentation and Billing Software with SMS / voice appointment reminders with a simple, easy and customizable layout – HIPAA and MIPS Compliant.

In Touch Billing – Drastically cut your billing costs & slash denials to maximize revenue without having to switch your EMR.

Eligibility Verification – Done-for-you patient benefit calls – make us an extension of your front desk. We’ll stay on the phone with the payer as long as it takes to get your benefits verified.

Therapy Newsletter – Done-for-you monthly email newsletter to patients and faxed, printed newsletter (evidence-based) for physicians where we do all the writing and delivery, and you take all the credit.

Clinical Contact – SMS marketing, voice broadcasting for your practice to drive your practice into the 21st century.

CARES Act Provider Relief Fund – Second Phase $20 Billion Distribution Update

The U.S. Department of Health and Human Services released an additional $20 billion toMedicare providers on 4-24-20. In order to qualify for this additional funding, some cost report data needs to be on file. This can be done retroactively through this CMS general distribution portal, and find out more on HHS FAQ page.

This amount will be distributed to providers based on 2018 net patient revenue based on cost reports submitted to CMS.

Eligibility – Providers who already received the first wave of stimulus money on or before 5.00 pm EST, April 24th can and should apply for additional funding via the provider relief fund application portal https://covid19.linkhealth.com/docusign/. Providers who have not received the first phase stimulus money are not eligible to use the provider relief fund application portal. However, providers who are not eligible for this stimulus package might qualify to receive funds from the provider relief fund through other mechanisms, including the targeted distributions being made from the fund.

The challenge for some clinicians, including PTs, is that they don’t typically submit cost report data to CMS. However, they still may qualify for relief funds according to HHS. Beneficiaries will receive email notifications from the HSS in the coming days. Even though the providers are expected to receive their money automatically, it is recommended that revenue information be submitted via the web portal https://covid19.linkhealth.com/docusign/

The payment process will be initiated as soon as all the information is validated. The first wave is to be delivered by end of this week.

Providers who receive funds from the general distribution have to sign an attestation confirming receipt of funds. Moreover, they also have to agree to the terms and conditions of payment and confirm the CMS cost report. https://covid19.linkhealth.com/

For additional information, visit https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/index.html.

CMS Suspends Advanced Payment Program and Re-evaluates the Accelerated Payment Program

Due to the COVID-19 pandemic, advanced payment programs were expanded in late March to provide emergency loans. CMS has now announced that they will suspend the advanced payment program for Medicare part B providers citing the availability of new relief money.

Also, CMS has decided to re-evaluate the accelerated payment program for Part A providers.

Unlike the money now being disbursed through a $175 billion CARES Act Provider Relief Fund (which does not need to be paid back pending attestations), the programs being curtailed by CMS required its beneficiaries to pay back the funds received.

According to CMS, the reason behind this change is mainly due to the infusion of $175 billion in relief funds to HHS. HHS is disbursing $50 billion to providers in the form of direct deposits that unlike the advanced payment program funds,do not need to be paid back.

OUTLINE OF SPECIFIC GUIDELINES ON E-VISITS & TELEHEALTH 

The Coronavirus Preparedness and Response Supplemental Appropriations Act, signed into law by the President on March 6, 2020, includes a provision allowing the Secretary of the Department of Health and Human Services to waive certain Medicare telehealth payment requirements during a Public Health Emergency (PHE). This allows beneficiaries across the country to receive telehealth services at home.

Under normal circumstances, physical therapy services are not authorized as telehealth services under Medicare, but a recent update from CMS indicates that several physical therapy CPT codes are now covered under telehealth temporarily due to the COVID-19 emergency.

Please note there is a difference between telehealth (a very broad term) and e-visits (a specific component of telehealth applicable under a specific situation).

Telehealth E-visit
DEFINITION Broad application, may or may not include clinical decision making Specific use-case (subset of telehealth) requiring clinical decision making
APPLICABLE PROVIDERS Originally intended for physicians & other healthcare providers. Effective 4-30-20, physical therapists can provide telehealth as per a recent CMS update. Recently applicable to physical therapy (as per CMS)
SCENARIO Broad scope – A visit normally done in the clinic, but now done remotely using audiovisual connections real-time, face-to-face with the patient. Narrow scope – A patient initiates an online assessment or management via HIPAA compliant, secure online portal. Neither real-time, nor face-to-face. Not intended for PT / OT treatment.
TYPE OF PATIENT New and established patient Normally, only for established patients. CMS recently expanded the scope to include new patients (as per the CMS interim final rule).
PAYER GUIDELINES CMS and several commercial payers may pay for physical therapy services as ‘telehealth’ (check with individual payers for payer-specific guidelines) CMS and Aetna pay for e-visits for physical therapists.
BILLING CODES Typical PT / OT codes (9-series codes like 97001, 97110, 97112, 97530 but not 97140) are appropriate. Commercial payers may accept these (check with each payer since some payers follow CMS guidelines and may accept HCPS codes) Use HCPS codes (G codes) for CMS. Can only charge one unit every 7 consecutive days regardless of how many e-visits were done in that 7-day period.
PLACE OF SERVICE Generally bill with place of service 02 for commercial payers and place of service 11 for Medicare(check with individual payers for payer-specific guidelines) Bill CMS with place of service 11 (from the clinic) or 12 (from home)
MECHANISM OF DELIVERY Delivered using multiple technologies including video conferencing and live chat. Delivered primarily using HIPAA-compliant patient portal (with broader provisions recently for non-public facing applications including Skype, Facebook messenger video chat, Facetime, Google hangouts and video conferencing tools like Zoom). Cannot use public facing applications like Facebook Live, Twitch, TikTok.

Before we explore telehealth and e-visit codes, please note they don’t pay very much, because they were intended for nominal reimbursement for telehealth in a ‘normal world’, where care might occasionally be rendered without an in-person visit. 

As a practical matter, these codes pay very little. Unfortunately, they will not help cover all your expenses and match your in-person visit reimbursements, considering the duration and 7-day period restrictions indicated in the CPT code description (see below).

We’ve had a lot of questions about billing out ‘regular codes’ through e-visits via video calls and it’s important to set the record straight. Guidance on this is constantly evolving, so make sure to bookmark this page and come back to it.

We recommend you update your website, send out an email broadcast, text messages and make outbound calls to announce to patients that Telehealth / e-visits are currently available. The goal is to educate patients and get them to initiate an Telehealth / e-visit.

E-Visit Guidelines with Medicare

Once a patient requests an e-visit, briefly document the patient request and the services rendered. Examples include any review of records, conversations with other caregivers and your clinical decision-making associated with the visit. Since the services may be intermittent over a seven-day period, briefly document all components of patient assessment and management performed during the time period. The time spent on e-visits is cumulative. This means that PT/OT can conduct multiple e-visits, but only bill the patient for one unit of one of these codes during a consecutive 7-day period. Note that this 7-day period begins when the therapist responds to the patient’s request for e-visit and ends after 7 consecutive days (it appears this includes weekends, and this is something we are currently trying to verify). In every subsequent 7-day period, a maximum of one unit of one e-visit code can be charged.

For example, if a PT had 4 e-visits with Mrs. Robinson during a 7-day period that cumulatively took 75 minutes, the PT can only bill one unit – G2063 – and will be paid a total of just under $34.

Use the code that best represents the cumulative amount of time spent in the e-visits (see examples below).

For Medicare, e-visits by physical therapists can be billed using these HCPCS codes:

G2061
Qualified non-physician health care professional online assessment, for an established patient, for up to seven days, cumulative time during the 7 days; 5-10 minutes

G2062
Same as above; 11-20 minutes

G2063
Same as above; 21 or more minutes

Payments to Expect from Medicare:

For G2061, the allowed amount is $12.01. 

For G2062, the allowed amount is $21.16.

For G2063, the allowed amount is $33.17.

The actual reimbursement from CMS will vary slightly depending on the location.

G2010
Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment.

G2012
Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.

Current guidance from CMS allows PT, OT and speech therapists to bill out HCPCS codes G2010 and G2012 on the CMS-1500 form. CMS does not allow PTA’s and OTA’s to perform these 2 virtual check-in services. 

CMS has designated the above-mentioned HCPCS Level II codes, in addition to G2010 and G2012 as “sometimes therapy” services. This means that the appropriate GP modifier along with CR should be used  on the CMS-1500 claim form for these services. The same also applies to some new CPT codes that CMS will pay for. CMS has designated telephone assessment and management service (CPT codes 98966, 98967 and 98968) as “sometimes therapy” services for PT, OT and Speech, which count towards the annual therapy dollar threshold. The appropriate GP or GO therapy modifiers must be respectively included on the CMS-1500 claim form for these services.

Understandably, these payments fall way short of rates that are common with outpatient services, but this is a step in the right direction for PT, OT and Speech.

Append modifier CR (catastrophe/disaster related) for Part B billing. Your reimbursement may vary slightly based on the state and the region within the state. For institutional billing, both the DR condition code and CR modifier are required. For non-institutional billing, the CR modifier is required.

Medicare will pay 80% of the allowed amount for the above mentioned HCPCS codes. We recommend you check with your State Medicare office to determine the exact allowed amount before billing out these codes.

APTA ADVOCACY UPDATE 4-30-20 – CMS Guidance Allows PTs in Private Practice to Provide Services Via Telehealth

According to a new announcement by the APTA, CMS will now include PTs in private practice among the providers able to bill for services provided through real-time face-to-face technology. 

New guidance issued by CMS now allows PTs in private practice to make full use of telehealth with their patients. 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.

A new list of CPT codes commonly used by PTs, OTs and SLPs has been added to the list of covered Medicare telehealth services during the COVID-19 pandemic. The entire list is available on the CMS website

The APTA states: 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.

Some of the physical therapy specific CPT codes covered under telehealth by CMS are as follows:

CPT Description
97161 PT Eval low complex 20 min
97162 PT Eval mod complex 30 min
97163 PT Eval high complex 45 min
97530 Therapeutic activities
97110 Therapeutic exercises
97112 Neuromuscular reeducation
97116 Gait training therapy
97164 PT re-evalest plan care
97535 Self-care management training
97750 Physical Performance Test
97150 Group therapeutic procedures
97542 Wheelchair management training
97755 Assistive Technology Assess
97760 Orthotic mgmt. &traing 1st en
97761 Prosthetic traing 1st enc

Modifiers for Telehealth:

GQ – when using an asynchronous telecommunications system

GT – When using a synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system. Note that some commercial payers may require the GT modifier in addition to POS code 02. Refer to individual payer guidelines since these are subject to change.

Modifier 95 – when providing synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system. 

As you can see, both GT and modifier 95 have a similar definition, but we have observed that different payers have different requirements. CMS requires the modifier GT for telehealth services. At In Touch Billing, we have observed that Modifier 95 is not recognized on the CMS-1500 claim form by either Medicare and Medicaid, and therefore it is commonly seen with commercial payers. Some commercial payers may require GT, others may require 95. Some payers require both GT and 95. Finally, some payers like the payer providence health plan of Oregon, Oklahoma have indicated they want neither GT nor 95.

Provider Enrolment: CMS has established toll-free hotlines for physicians, non-physician practitioners including physical therapists, establishing isolation facilities to enroll and receive temporary Medicare billing privileges.

Providers should only contact the hotline for the MAC that services their geographic area.

The hotlines are operational Monday – Friday at the specified times below:

1. CGS Administrators, LLC (CGS)

Call: 1-855-769-9920

Hours of Operation: 7:00 am – 4:00 pm CT

2. First Coast Service Options Inc. (FCSO)

Call: 1-855-247-8428

Hours of Operation: 8:30 AM – 4:00 PM EST

3. National Government Services (NGS)

Call: 1-888-802-3898

Hours of Operation: 8:00 am – 4:00 pm CT

4. National Supplier Clearinghouse (NSC)

Call: 1-866-238-9652

Hours of Operation: 9:00 AM – 5:00 PM ET

5. Novitas Solutions, Inc.

Call: 1-855-247-8428

Hours of Operation: 8:30 AM – 4:00 PM EST

6. Noridian Healthcare Solutions

Call: 1-866-575-4067

Hours of Operation: 8:00 am – 6:00 pm CT

7. Palmetto GBA

Call: 1-833-820-6138

Hours of Operation: 8:30 am – 5:00 pm ET

8. Wisconsin Physician Services (WPS)

Call: 1-844-209-2567

Hours of Operation: 7:00 am – 4:00 pm CT

CMS is providing the following flexibilities for provider enrolment:

  •  Postpone all revalidation actions.
  •  Allow licensed physicians and other practitioners including physical therapists to bill Medicare for services provided outside of their state of enrollment.
  •  Expedite any pending or new applications from providers.
  •  Allow practitioners to render telehealth services from their home without reporting their home address on their Medicare enrollment while continuing to bill from your currently enrolled location.
  • Allow opted-out practitioners to terminate their opt-out status early and enroll in Medicare to provide care to more patients.

Recent Updates to Medicaid Telehealth Coverage

Medicaid programs have issued varying guidance on PT and rehabilitation telehealth services across different states. Although each state’s laws, regulations, and Medicaid program policies differ significantly, Medicaid has started  to expand the physical therapy services covered by telehealth, based on the status of the COVID-19 epidemic in the state. It is expected that Medicaid will further expand telehealth coverage for physical therapists based on the recent announcement by Medicare that physical therapists are now eligible providers to perform telehealth services.

Many states are expanding their access for Medicaid patients via telehealth and it’s best to monitor your state Medicaid website. It is imperative to check if PT/OT services are included and if PTs are permitted providers. In some cases, Medicaid mentions codes (98966, 98967, 98968) that are generally used by non-physicians. However, there is no clear guidance for PT/OT. Therefore, it is best to check with each state for updated guidelines. Additionally, some state Medicaid programs have begun incorporating specific documentation and/or confidentiality, privacy and security guidelines within their documented manuals for telehealth.

Visit your state Medicaid agency website to search for your state’s current telehealth covered services under Medicare payment policy. For more information, visit:

https://medicaiddirectors.org/about/medicaid-directors/

Below, we have outlined state-specific Medicaid coverage information. This is breaking news and it is subject to change, and we advise you to verify this information with your state Medicaid agency before billing out these codes. Although physical therapy CPT codes are increasingly covered, we have not yet established if physical therapists are considered ‘telehealth providers’ by Medicaid.

Colorado Medicaid

Colorado department of healthcare policy and financing has expanded Medicaid policy to include the use of physical therapy codes for telehealth (and expanding the definition of telemedicine services to include telephone only and live chat modalities). The codes that would normally be billed in an in-office visit can potentially be billed out through telehealth.

Florida Medicaid 

Florida Medicaid will reimburse for evaluation, diagnostic, and treatment recommendations for services included on the respective therapy services fee schedule.The services can be delivered in a manner that is consistent with the standard of care and all service components designated in the American Medical Association’s Current Procedural Terminology and the Florida Medicaid coverage policy. Physical therapists must append the GT modifier to the procedure code in the fee-for-service delivery system. We recommend that you check with Florida Medicaid to determine the list of covered CPT code for physical therapy services.  

Louisiana Medicaid 

Louisiana Medicaid has included all Louisiana Medicaid managed care organizations to cover telehealth services for physical therapists. The CPT codes covered by Louisiana Medicaid are 97161, 97162, 97163, 97164, 97110, and G0151. Physical therapists need to bill telehealth claims with place of service 02 and modifier 95.    

Michigan Medicaid

Michigan Medicaid covers CPT code 97110, 97112, 97116, 97530 and 97535 under telehealth and the place of service should be 02 with modifier 95. This expanded telehealth coverage as a result of the COVID-19 emergency is effective until June 30 according to Michigan Medicaid.

NY Medicaid

NY Medicaid covers CPT code 99441-99443 for physical therapy under telehealth. The payment is 150% of the 2020 Medicare fee schedule effective for dates of service on and after March 13.

Medicare has required Medicare Advantage plans to expand telemedicine benefits. Most of the MA plans are required to follow in the footsteps of CMS.

The telehealth and PT reimbursement rates and guidelines for commercial payers vary, and are constantly changing. They are discussed below.

General Telehealth / E-Visit Guidelines with Commercial Payers

For CMS and commercial payers like Aetna, e-visits by physical therapists can be billed using the following CPT codes:

98970
Qualified non-physician health care professional online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes

98971
Same as above; 11-20 minutes

98972
Same as above; 21 minutes or more

APTA Guidance on Questions to Ask Commercial Payers about Telehealth

Talk to your commercial payer to confirm if they will reimburse for the above mentioned codes, since some codes are plan specific. Guidelines are changing rapidly as the COVID-19 outbreak continues to evolve. The APTA has released guidance on which questions to ask commercial payers.

1. Will services provided by physical therapists (and PTAs working under the direction and supervision of the PT) be covered when provided via telehealth?

2. If so, what codes should be billed and what modifiers are required?

3. What device(s) or application(s) can be utilized?

4. What, if any, consents are required?

5. Are there any special documentation requirements?

We believe it makes sense to ask a couple more questions

6. Current guidance indicates that most commercial payers will only pay for current patients (like CMS), however this may change at any time. Therefore, it’s worth asking – Will they pay only for current patients or new patients (including evaluations)?

7. Will they only pay for in-network providers? For out-of-network providers, will they pay the out-of-network benefit amount?

In addition to the above CPT codes, additional telehealth / e-visit codes may be covered by some commercial payers. Each payer has specific guidelines about telehealth / e-visit codes. 

Any limitations on e-visit services for commercial payers depend on the individual member plan. For most commercial payers (check with each payer), the POS for telehealth services should be 02 with GT / 95 / GQ modifiers depending on the payer. However, we recommend that you verify this information with each commercial payer, since they may or may not follow CMS guidelines. This will help you determine whether to bill out as telehealth, or e-visits.

Specific Telehealth Announcements from Major Commercial Payers

Our team is gathering information daily from commercial payers about telehealth services for physical therapists and the information below will be updated in real-time. 

Disclaimer – While the In Touch Billing team does it’s best to provide you with real-time information, it’s impossible to keep up with every change across all payers. We are not responsible for any changes / updates made by CMS and other payers since guidelines are changing daily, so it is the responsibility of your benefit verification team to verify the benefits for each patient, for their specific plan and ask about the requirement for pre-authorizations before providing telehealth or e-visits. Commercial payers have different policies that change from time to time, and may or may not follow CMS guidelines

1. United Healthcare – FIRST MAJOR PAYER TO SUPPORT TELEHEALTH FOR PT/OT

United Healthcare will reimburse physical, occupational and speech therapy telehealth services provided by qualified health care professionals when rendered using interactive audio/video technology. This is applicable for all Medicare Advantage, commercial and managed Medicaid plans, for new and established patients. State laws and regulations apply. Benefits will be processed in accordance with the member’s plan. This change is effective immediately for dates of service March 18 through June 18, 2020. UHC is now paying for telehealth services for institutional claims billed via the UB04 claim form. UHC will require revenue code 780 when telehealth services are billed. Contact UHC if you have any additional questions on how to bill telehealth services in UB04 form.

UHC has expanded telehealth coverage. Billable codes include initial evaluations, re-evaluations, 97110, 97112, 97116, 97530, 97535, 97750, 97760 and 97761. The good news is that the rates are still the same as an in-office visit. There had been no clear guidelines with regards to PTAs and COTAs, but if the guidelines are similar to an in-office visit, PTAs and COTAs they should still be able to see UHC commercial and Medicaid patients as if it is an in-office visit, except for Medicare Advantage patients. For more details, visit UHC’s page on COVID-19 Physical, Occupational and Speech Therapy Telehealth.

Click here to view the list of CPT codes covered by UHC for PT, OT and Speech Therapy.

2. Aetna expands Telehealth coverage by PTs

The following are nationwide Aetna rules, including Aetna’s Medicare Advantage and commercial plans. An audio-visual connection is required, and there is no specific guidance about a preferred communication platform. Skype, facetime or zoom can be used. Aetna covers telehealth services for both new and established patients.

The insurer, officially known as CVS Health/Aetna, will cover the telehealth based delivery of the services and procedures by PTs for CPT codes 97161, 97162, 97163, 97164, 97110, 97112, 97116, 97535, 97755, 97760, and 97761. Providers are required to append the GT modifier to the codes. As far as we can tell, Aetna is not allowing 97530 but it’s best to check with Aetna since things might change.

Outpatient PT / OT and speech clinics who submit claims via the CMS-1500 form should use place of service 11 with modifier 95 when billing Aetna. It also appears that rehabilitation facilities using a UB-04 claim form can provide telehealth services to Aetna beneficiaries and get reimbursed for them. We recommend that you contact Aetna for specific guidelines on how to bill telehealth services via UB04 form.

Aetna will allow PTs to bill e-visits only (not telehealth) using either G2061-G2063 or 98970-98972. Therefore, it is important to verify benefits directly with Aetna prior to providing telehealth services. Aetna may require clinical records during the claim submission process. It appears Aetna will cover 100% for both in-network and out-of-network providers for the next 90 days. It also appears there is no copay, deductible or coinsurance requirement.

Aetna will pay for Medicare type e-visits and G codes (G2061-G2063). Providers are not restricted to the use of G codes. The good news is that providers have the additional option to use similar CPT codes (98970-98972). The use of the GT or 95 modifier is not required for e-visit CPT codes.

In either case, the reimbursement rates are going to be low relative to an in-person visit and an ‘audiovisual connection’ must be used. However, there are situations where only a telephone connection may be available. In such situations, Aetna will pay for 98966, 98967 and 98968 (telephone assessment and management services).

By definition, these services must be provided by a qualified non-physician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 5-10; 11-20; or 21-30 minutes of medical discussion.

3. Cigna also expands Telehealth coverage by PTs

Cigna announced a series of temporary changes that open the doors for telehealth by PTs, occupational therapists, and speech-language pathologists. CIGNA also covers PT/OT telehealth visits for all Medicare Advantage and commercial plans for new and established patients and an audio-visual connection is required. Reimbursement rates are the same as an in-office visit. PTAs and COTAs can see commercial patients but not Medicare Advantage patients. CIGNA has expanded the number of billable codes that can be used. Cigna allows for reimbursement of 97161-97164, 97110, 97112, 97116, 97535, 97750, 97755, 97760 and 97761. Codes must be appended with a GT, GQ or 95 modifier and billed with a standard place-of-service code 11. Cigna recommends that providers follow CMS guidance on the use of a specific software program but states that it will not require the use of a specific software for now. For more details, visit Cigna Coronavirus (COVID-19) Interim Billing Guidance for Providers for Commercial Customers.

4. BCBS

BCBS guidelines differ by state and we recommend signing up for email updates from your local BCBS carrier and monitoring their state guidelines here. At In Touch Billing, we have called several BCBS payers in different states and revealed our findings in the sections to follow. We have been notified by clients that BCBS of North Carolina and BCBS of Texas have announced that they are covering PT/OT telehealth visits with the same guidelines and reimbursement rates as in-office visits.

For Florida Blue, CareCentrix (their provider) is playing a big role by covering telehealth visits through home health agencies and this includes OT, PT and SLT services. Click here for Florida BCBS guidelines.

BCBS of Rhode Island just made an announcement about telehealth and e-visit coverage. Several temporary changes to telemedicine/telehealth policies have been made to allow for telephone only services. The goal is to ensure that BCBS members are able to access appropriate care from providers.

The new changes are effective for dates of service on or after March 18, 2020. It appears these changes are in effect until Friday, April 17, 2020. Based on these updates, physical therapists are allowed to provide telemedicine/telehealth or telephone only services. Keep in mind that physical therapists cannot bill for services like manual therapy which need in-person interaction with the patient. Services must be suitable for delivery via telemedicine and/or telephone, be clinically appropriate and medically necessary and otherwise covered under the member’s benefit plan or subscriber agreement.

It appears that prior authorization is not required for such services at the present time. BCBS RI will reimburse telemedicine/telehealth or telephone only encounters at 100% of the in-office allowable amount for any clinically appropriate, medically necessary covered health service. BCBS RI will temporarily waive cost-share (e.g.co-pays and/or deductibles and co-insurance) for services provided by physical therapists.

Services may be provided via the following non-HIPAA compliant secure electronic communication applications that allow for video chats:

  • FaceTime
  • Facebook Messenger video chat
  • Google Hangouts video
  • Skype

For state and county-specific information, check with local BCBS provider services.

5. Triwest

Triwest covers physical therapy telehealth services, depending on the patient’s plan. Similar to Aetna, Triwest is more flexible in terms of mode of communication, including skype, facetime or zoom. Consents or special documents are not required, however Triwest will require prior authorization for all the patients availing a telehealth service. Triwest requires modifier 95 and the place of service should be 11.

6. Tricare

PTAs are now recognized as authorized providers by TRICARE

In a recent policy change, Tricare has indicated that the PTAs are authorized providers to provide services covered by Tricare and thus they are eligible for reimbursement for the services rendered. Most importantly, the CQ modifier must be appended to the claim if more than 10% of an outpatient physical therapy service is furnished by the PTA.

According to Tricare, PT/OT can be performed via telemedicine for an established patient with the same rates as an in-office visit but not for new patients. The patient has to be established, which means that the initial evaluation was done in the clinic, and follow up treatments and visits were done via telehealth. Tricare has indicated that the same referral/authorization requirements that are in place with an in-office visit are in place with telehealth visits, which requires the same level of coordination with the referring physician. For synchronous telemedicine services, bill using either CPT codes or HCPCS codes with a GT modifier for the distant site and Q3014 for the originating site to distinguish telemedicine services. Use place of service “02” in conjunction with the GT modifier. The same modifiers normally used in an in-office visit can be used for telehealth. For asynchronous telemedicine services, bill using CPT or HCPCS codes with a GQ modifier and place of service “02.”

Note: You may indicate “Signature not required – distance telemedicine site” in the required patient signature field on the claim form.

7. BCBS NY, WY and Ohio Aetna 

May allow physical therapists to bill CPT codes 99441-99443 via telehealth. This coverage is state specific and you need to check with your payer.

8. BCBS of Michigan

May pay for CPT codes 97110, 97112, 97116, 97530 and 97535 via telehealth effective for both commercial and Medicare Advantage population until June 30. At Therapy Newsletter, we have observed several BCBS plans in different states allow for the reimbursement of 97112, but it’s best to check specific plans.

9. Payer Providence Health Plan of Oregon, Oklahoma

May allow physical therapists to bill 92507, 92526, 92609, 97110, 97112, 97129, 97130, 97161, 97162, 97163, 97530, 97535 via telehealth. 2-way video services performed by PTs for services within the scope of license may be covered. The POS should be 02. Do NOT append GT or 95 modifier. Append modifier GQ. It appears that payment is allowed only when provider originating site is used.

10. Payer Independence Blue Cross of Southeast PA

May cover CPT codes 97110, 97112, 97116, 97129, 97130, 97161, 97162, 97163, 97164, 97165, 97166, 97167, 97168, 97530, 97533, 97535 for physical therapists. The POS should be 02 and modifier GT or 95 is required in the claim.

11. Regence Blue Cross of WA and Premera Blue Cross of WA

May pay for 97000 series codes at contracted rates. We recommend that you check with the payer for specific CPT code coverage information.

12. Anthem Blue Cross – CA

Normally, physical therapy services require face-to-face interaction and therefore are not appropriate for telephone-only consultations. All Anthem contracted providers can provide telehealth services if clinically appropriate. For telehealth services, providers should bill the same CPT codes that they would normally bill for in-person visits, with modifier GT and POS code 02.

13. Anthem Blue Cross – WI

Coverage of telehealth therapy evaluation only; does not include treatment. Claims should be billed with POS code 02, Modifier 95 or GT, and the appropriate CPT code. Anthem will cover the initial evaluation, which should be provided through a certified telehealth platform including video and audio.

14. BCBS- Louisiana

 Any credentialed network physical therapist can provide limited telehealth encounters to replace office visits. Therapy providers must adhere to telehealth guidelines. Therapy providers filing claims for telehealth should use standard office billing practices and CPT codes along with POS code 11 and Modifier GT or 95. Telehealth therapy services are limited to the following CPT codes: 97161, 97162, 97164, 97110, 97112, 97116, 97530, 97535, 97165, 97166, 97168. Claims will be paid using standard member cost shares.

15. BCBS- Massachusetts

BCBS of Massachusetts reimburses contracted health care providers for covered, medically necessary telehealth (telemedicine) services. When you provide services via telehealth, you are not restricted to specific telephonic CPT codes. You may be able to bill all covered services that you render either by telehealth/video or telephone as if you are performing a face-to-face service using the codes that are currently on your fee schedule. You must use one of the following telehealth modifiers: GT, 95, G0, and GQ and use POS 02.

16. Independence Blue Cross

This payer has expanded telemedicine to physical therapists which should be done via video conferencing. We recommend that you check with the payer for the list of covered CPT codes.

17. Kaiser Permanente

Payer Kaiser Permanente allows telephone and video visits by physical therapists. We recommend that you check with the payer for the list of covered CPT codes.

18. Vantage Health Plan

Physical therapy visits performed through telemedicine must be in lieu of a face-to-face visit for an established patient with an existing plan of care. Physical therapists should bill these telemedicine visits with CPT 97110 (therapeutic exercise) with the appropriate modifier GP or GO. Vantage Health Plan allows up to three PT and three OT units per week per patient. These claims must be billed with a POS code of 02 instead of POS 11. Vantage will pay these telemedicine claims at the current allowable with NO patient cost share.

19. Humana

Humana will allow e-visits for Medicare Advantage plan members. They are currently following CMS guidelines and allow e-visits for PTs and not PTAs.Use modifier 95 and POS 11 (office) or 12 (home). Humana covers telephonic assessment codes 98966-98968 and follows Medicare guidelines. It is our opinion that Humana will make a formal announcement once CMS recognizes PTs as telehealth providers. They haven’t issued any specific guidelines on commercial plans, so we advise you to call Humana and ask for guidance about specific plans.

20. American Specialty Health

American Specialty Health covers telehealth services for physical therapy services CPT codes 97161, 97162 and 97110. The recommended place of service is 11 and the modifier GQ is recommended.  PT’s can initiate telehealth lists for new and established patients. PTAs are allowed to perform telehealth services if the service is performed under the direct supervision of a PT. Both in-network and out-of-network providers are eligible to perform telehealth services.

21. Allways Health Partners

Allways Health Partners cover telehealth services for physical therapy services CPT codes 97161, 97162, 97163, 97164, 97110, 97530 and 97535. The recommended place of service is 02 and the modifier GT is recommended.  PT’s can initiate the telehealth lists for new and established patients. PTAs are allowed to perform telehealth services if the service is performed under the direct supervision of a PT. Both in-network and out-of-network providers are eligible to perform telehealth services. Video and audio communication is recommended by this payer.

Telehealth Considerations for Workers Compensation Claims

As COVID-19 forces the lockdown of many physical therapy clinics across the country, worker’s compensation payers are covering more telehealth services to keep injured worker care on track. Telehealth services provide injured workers with an opportunity to continue their care even as brick and mortar clinics temporarily close their doors.

The guidelines still differ state by state and often carrier by carrier basis so please check individual websites about the COVID-19 update. Regardless of whether the state is providing guidance or not, it is essential to contact the case manager in order to get telehealth approved for reimbursement. Similar to the recommended list of questions for commercial payers set forth by the APTA, we recommend a set of questions when talking to case managers.

  • Is PT / OT covered via telehealth?
  • How many “visits” are allowed?
  • Can visits be done by phone / patient portal / is audio/visual required?
  • What codes can be used and are there specific modifiers or POS that must be used?
  • Do authorization, copay, deductibles apply like in-office visits?
  • Can PTAs and COTAs perform care via telehealth and get reimbursed?

MedRisk’s tele-rehab program, which has been running for almost three years, combines in-person visits with video conference visits.

Here is some state specific information from the team at Therapy Newsletter:

NY Workers Compensation

NY Workers Compensation allows physical therapists to bill CPT 99441 with place of service 02 and modifier 95 for telehealth services. The services should be medically appropriate.

 KY Workers Compensation

KY Workers Compensation states that telehealth services may be offered when clinically appropriate in the judgment of a physical therapist, for treatment of workplace injuries and occupational disease. Modifier 95 should be appended to the CPT code.

Further, KY WC regulations state that patients with emergent or urgent conditions are not considered for telehealth services in the acute phase of their recovery. The reason is that these patients are at increased risk for a lifetime of disability if physical therapy services cannot be performed in-person with a licensed physical therapist.

Every day, an increasing number of workers compensation payers are starting to cover telehealth services for physical therapists. We recommend you contact the claims adjuster to determine payer specific coverage information before you treat patients and bill out claims.

Telehealth Considerations for State-Regulated Payers

Several states are issuing guidelines to expand telehealth. Several states such as Massachusetts, California, Illinois and Arizona have taken the lead. States have announced that all telehealth visits must be reimbursed at the same reimbursement rates as in-office visits. Click here to check state-specific guidelines regarding telehealth.

MIPS Date Submission Deadline Extended

Clinicians and facilities participating in CMS quality reporting programs, including the Merit-based Incentive Payment System (MIPS) will have more flexibility with data submission.

For the MIPS program, 2019 data submission deadlines have been moved to April 30. The previous deadline was March 31.

Telehealth Examples for Physical Therapists – Lots to Do!

  • Provide quicker screening, assessment, and referrals to improve care coordination. 
  • Provide interventions by observing patient movement and function to facilitate proper exercise technique including range of motion. Verbal and visual instructions / cues to help the patient perform various activities. Modification of the patient environment to minimize injury and facilitate functional outcomes.
  • Participate in a joint effort with other health care providers for specific movement-related activities, to optimize the patient’s participation and encourage functional recovery.
  • Quick check-ins with established patients, when a comprehensive in-person visit may or may not be appropriate or possible.Currently, most of the payers including Medicare are allowing evaluation visits via telehealth services.

Recommended Telehealth Platforms – Options to Consider

Providers may use non-public facing remote audio and/or video communication services to communicate with their patients. These services include, but are not limited to:

  • Facetime
  • Skype
  • Doxy.me
  • Updox
  • Zoom for Healthcare
  • Skype for Business
  • VSee

Providers may not use public-facing services, such as Facebook live, Twitter or TikTok.

HIPAA Considerations with Telehealth

Effective March 17, 2020 through the end of the COVID-19 public health emergency, the Office for Civil Rights (OCR) will not impose penalties on providers for their failure to comply with the Health Insurance Portability and Accountability Act (HIPAA) while providing telehealth services in good faith to their patients, providing they use non-public facing remote communication technology to provide the services. Providers using non-HIPAA compliant services are encouraged to notify patients about potential privacy risks.

Final Note – Time to show Strength & Leadership by Giving Patients Much-Needed Hope

In a time of strife, the strong demonstrate strength and emerge stronger. The weak need help, and need leaders. Use this time to reach out to patients and tell them you can help them through e-visits, and that you will re-open as soon as the situation allows. Show leadership and solidarity. Give patients hope, and lead the way.

Use email newsletters with Therapy Newsletter, text messaging and voice broadcasts with Clinical Contact and make announcements on your website to get the word out quickly. There’s no need to call patients one by one, although you certainly can.

Also use this time to build systems, create written processes and do the things you don’t normally have the time for. Switch to an EMR software like In Touch EMR, or switch to a new, improved billing service like In Touch Billing to improve your collections and reduce denials.

“Use email / SMS / voice broadcasting / website announcements to project strength & solidarity with patients”

Here’s a script you can use and change as needed:

Dear Patient, although we live in uncertain terms, you can count on us to continue taking care of your health and well-being. The good news is – we can provide you with physical therapy services via telehealth effective immediately. Contact our office at xxxx or email us at xxxxx to schedule a telehealth visit, which may be covered by your insurance. You can also change an upcoming appointment to a telehealth visit if you so choose. Telehealth is very convenient – you can use your phone (Android or Iphone) or computer connected to the internet to complete the visit. Our office will advise you of next steps to take once the visit is scheduled. Slots are filling up fast, so contact us now. As soon as we’re open, we’ll take great care of you in the office, like we always have. You are not alone, and you can always count on us to be here for you. Call us if you need anything, we will answer the phone and we can’t wait to talk to you!

Therapy Newsletter’s CRU is designed to act as your shield against this unavoidable pandemic. 

As a community, it’s time for bold, aggressive measures now. There has never been a more pressing time.

If you have any questions or need any help, get in touch with us:


Email:
janice@referralignition.com or
patrice@referralignition.com

Call:
973-797-9286 or
1-800-421-8442 extension 2

Send us a text message: 413-489-2067

Click here to initiate a phone call with us

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Click here to comment, like or share our Linkedin article

Send me a message on Linkedin. If we aren’t yet connected on Linkedin, connect with me on Linkedin now, and message me. I’ll share my cellphone with Linkedin contacts who reach out to me via Linkedin messaging, if you need to call or message me directly.


Sincerely,

Nitin Chhoda PT, DPT
CEO, Therapy Newsletter

Additional Resources:

Coronavirus Waivers & Flexibilities page of the CMS website
Coronavirus updates from the APTA
APTA document – Federal Payer Telehealth or E-Visits Coverage
APTA document – Commercial Payer Telehealth or E-Visit Coverage
APTA document – State-Mandated Executive Orders Related to Telehealth
APTA document – State Emergency Orders Permitting PTs to Provide Telehealth Services
APTA document – Occupational Medicine Providers Telehealth or E-Visits Coverage
Employee considerations during COVID-19 for PT practices
Difference Between Exempt and Nonexempt Employees
Reducing Exempt Employee Payroll in Response to Coronavirus Uncertainty
CMS guidance on telemedicine
Triwest VA Choice guidance on telemedicine
TriCare guidance on telemedicine
COVID-19 resources from CVS for Aetna members
Aetna provider page guidance on telemedicine
COVID-19 announcement from Aetna for all providers