On April 2nd, NASL, ASHA, AOTA, and APTA submitted a letter to Secretary of Health & Human Services Alex Azar and Centers for Medicare & Medicaid Services (CMS) Administrator Seema Verma asking them to issue a blanket waiver expanding the types of providers eligible to furnish telehealth services under Medicare to include physical therapists and physical therapist assistants, occupational therapists and occupational therapy assistants and speech-language pathologists during the COVID-19 public health emergency. The Coronavirus Aid, Relief & Economic Security Act (CARES Act) allowed for increased use of Telemedicine for many providers but did not include PT, OT, and Speech. Very recently, several non-Medicare payers have indicated that they would reimburse for therapy services through Telemedicine. ONR is preparing for the possible use of Telemedicine services in the future.
Types of Telehealth/Telemedicine
There are three main types of virtual services: Medicare telehealth visits, virtual check-ins, and e-visits.
MEDICARE TELEHEALTH VISITS: Currently, Medicare patients may use telecommunication technology for office, hospital visits and other services that generally occur in-person. For therapy, it could include all evaluation and treatment, including supervisory visits.
- The provider must use an interactive audio and video telecommunications system that permits real-time communication between the distant site and the patient at home.
- Distant site practitioners who can currently 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.
VIRTUAL CHECK-INS: Established Medicare patients in their home may have a brief communication service with practitioners via a number of communication technology modalities including synchronous discussion over a telephone or exchange of information through video or image.
- Medicare pays for these “virtual check-ins” (or Brief communication technology-based service) for patients to communicate with their doctors and avoid unnecessary trips to the doctor’s office. These virtual check-ins are for patients with an established relationship with a physician where the communication is not related to a medical visit within the previous 7 days and does not lead to a medical visit within the next 24 hours.
- Doctors and approved practitioners may bill for these virtual check-in services furnished through several communication technology modalities, such as telephone (HCPCS code G2012). The practitioner may respond to the patient’s concern by telephone, audio/video, secure text messaging, email, or use of a patient portal. Standard Part B cost-sharing applies to both. In addition, separate from these virtual check-in services, captured videos or images can be sent to a physician (HCPCS code G2010).
E-VISITS: In all types of locations including the patient’s home, and in all areas (not just rural), established Medicare patients may have non-face-to-face patient-initiated communications with their doctors without going to the doctor’s office by using online patient portals. An example of this is messages exchanged by a patient and physician.
- 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.
- The services may be billed using CPT codes 99421-99423 and HCPCS codes G2061-G2063, as applicable. The patient must verbally consent to receive virtual check-in services. The Medicare coinsurance and deductible would apply to these services.
Here is a summary of Telehealth/Telemedicine services:
|Type of Service||What is the Service?||HCPCS/CPT Code||Patient Relationship with Provider|
|Medicare Telehealth Visits||A visit with a provider that uses telecommunication systems between a provider and a patient||Common telehealth services include:|
Click here for a complete list.
|For new* or established patients.|
*To the extent the 1135 waiver requires an established relationship, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency.
|Virtual Check-In||A brief (5-10 minutes) check in with your practitioner via telephone or other telecommunications device to decide whether an office visit or other service is needed. A remote evaluation of recorded video and/or images submitted by an established patient.||HCPCS code G2012|
HCPCS code G2010
|For established patients|
|E-Visits||A communication between a patient and their provider through an online patient portal||For established patients|