The following is information from the NASL call and our professional organizations regarding options for use of remote visits during this COVID-19 restriction time. Please note that remote visits should only be used in circumstances where there is no other option. Any deviation from ONR usual protocol for supervisory or other visits should be discussed with the DOR/EDO prior to initial of the remote visit.
Utilizing audio-visual services in place of an in-person visit
This is our collaborative interpretation of comments made by Emily Yoder of CMS. Centers for Medicare & Medicaid Services (CMS) staff has stated that therapists, including PT, OT and SLPs, may provide evaluation and treatment services to patients in skilled nursing facilities (SNFs) via audiovisual devices. These services, for billing purposes, would be considered in-person services when provided in the same building as the patient. Here are some specifics:
- Click this link for the specific reference.
- The evaluating therapist must be in the same building as the patient but would not be in the same room.
- The therapist can use their phone or computer to communicate with a patient.
- The patient would be in another room with an assistant and both would communicate with the evaluating therapist. There is some disagreement as to whether the assistant needs to be there, but I will update as needed.
- This visit could serve as a supervisory visit or be used for evaluation and treatment.
- The visit would be billed under regular therapy codes depending on the services. Telehealth codes would NOT be used for this type of visit.
Use of delayed participation for the supervisory 10th visit
- This type of visit should be used when the evaluator cannot come on-site for the supervisory visit due to patient safety concerns related to COVID-19. Whenever possible, regular 10th visit protocol should be used with the therapist on-site and participating in the visit.
- In the case of delayed participation, the evaluator reviews the documentation remotely and speaks with the assistant who is with the patient via phone. The therapist communicates about the patient and the plan of care, provides guidance to the assistant and updates the POC remotely.
- The evaluator will document “therapist participation in treatment for the supervisory visit was not possible due to the COVID-19 pandemic and concerns for patient safety.”
- Be sure that your EDO is aware that this type of visit is being used.