Medicare Reimbursement for SOME Remote PT Services During COVID

Billing for Medicare/CMS for Remote Visits

Typically Medicare does not pay for Physical Therapy visits done remotely. However, in the wake of COVID-10, CMS has issued waivers during the emergency and based on the most recent guidance, this appears to cover Physical Therapy Visits across the entire Country, not just rural areas. Please note that this is a temporary order, it's not clear how long it will last.CMS is expanding this benefit on a temporary and emergency basis under the 1135 waiver authority and Coronavirus Preparedness and Response Supplemental Appropriations Act.It's important to note that Medicare still doesn't cover PT Telehealth but they do cover what they call "e-visits". E-visits are NOT telehealth. With that said, these are interactions that you can perform remotely. Allowing these remote interactions is a step in the right direction. It may be splitting hairs but Medicare always has their own terminology.

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. 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.Medicare

and further

Clinicians who may not independently bill for evaluation and management visits (for example – physical therapists, occupational therapists, speech language pathologists, clinical psychologists) can also provide these e-visits and bill the following codes: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 minutesG2062: 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 minutesG2063: 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.Medicare

Key takeaways, according to Medicare. This is really important:

• 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.
• Medicare coinsurance and deductible would generally apply to these services.

There are also many other unknowns such as how much will be paid on these codes and if any modifiers need to be applied. Based on the information available it does not appear that these reimbursements will take the place of regular in-person visits for providing care or in terms of revenue for practices - but it's something.

Putting Medicare E-Visits (and other efforts towards telehealth) in Place

There may be a great need in your practice to move towards e-visits given the current situation but make sure to keep mind of basics as you move forward:1) We strongly suggest that you work with a HIPAA compliant platform though Medicare seems to hint that you could use a Skype or a Facetime type product if you wanted:

"HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (HIPAA): Effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency. "Medicare

2) Continue to document thoroughly in your EMR all visits including those provided over a telemedicine/telehealth platform. As this is a very new change for PTs, OTs, and SLPs - documentation is paramount.3) Make sure you are communicating with your patients regularly and ensure that they are comfortable, to the extent that you can As with any technology, the feasibility of implementing on your practice depends on your operations, therapists, patients, etc. It is suggested that you really evaluate the pros and cons of offering e-visits, telehealth to patients.

The Bottom Line

Things are evolving very quickly and we will continue to provide updates as the information becomes available.