EDITOR’S NOTE: This article has been updated to included UnitedHealthCare’s late Thursday night policy change.
The therapy world as we know it has been transformed in the era of COVID-19.
Questions surrounding the definition of essential healthcare personnel (HCP), 1:1 care, e-visits, and telehealth are evolving daily and are leaving many rehab professionals and providers struggling to understand the regulations.
Today I am here to help.
You think I am braving this piece alone?
I must give much praise to our therapy tri-alliance in the American Physical Therapy Association (APTA), American Occupational Therapy Association (AOTA) and the American Speech-Language-Hearing Association (ASHA), which have been gracious to prepare and send me systematic links to the most up-to-date info in addition to the wealth of material and resources that are being compiled and updated daily from the American Health Care Association.
Topic 1: Telehealth
Oh, the confusion and misinformation around telehealth.
Myth: “President Trump’s declaration is allowing for therapy telehealth.”
Myth: “I heard from a Medicare rep that all we have to do is add a modifier.”
Fact: Currently, therapy codes are not considered to be a billable service under traditional Medicare for telehealth.
Can therapists perform telehealth services under Medicare?
No, therapists are still statutorily excluded from true telehealth services in Medicare at this time. Although Medicare will not currently reimburse these services, some private payers may. Therefore, consult with your payer for the most current telehealth guidelines.
Update: Effective 11 pm CDT on March 26, 2020: United Healthcare released the following updates on its policies concerning telehealth and therapy services:
“UnitedHealthcare will reimburse physical, occupational and speech therapy telehealth services provided by qualified healthcare professionals when rendered using interactive audio/video technology. 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.
“Reimbursable codes are limited to the specific set of physical, occupational and speech therapy codes listed here. UnitedHealthcare will reimburse eligible codes when submitted with a place of service code 02 and modifier 95.”
What is my therapy society doing to advocate for the use of telehealth?
The President’s announcement DID, however, allow for therapists to access the physician e-visit codes.
Topic 2: E-visits
Background: On March 17, 2020, CMS announced that physical therapists, occupational therapists and speech-language pathologists can use the digital assessment codes (e-visits) created in the 2020 Medicare Physician Fee Schedule (MPFS) final rule.
What is an e-visit?
The 2020 Medicare Physician Fee Schedule describes e-visits as non-face-to-face “patient-initiated digital communications that require a clinical decision that otherwise typically would have been provided in the office.”
The Medicare G-codes for e-visits are G2061-G2063 and include very specific parameters to determine whether an e-visit can be included on a Medicare Part B (outpatient) claim for payment.
- G2061: Qualified non-physician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the seven 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 seven 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
Is an e-visit a telehealth service?
No. An e-visit is considered a service furnished remotely using technology but is not considered a Medicare telehealth service. Under Medicare, therapists are still not recognized as telehealth providers. An e-visit does not constitute telehealth under the Medicare definition. Under commercial payer policies, the answer varies. Therefore, check with your payer.
What are the billing requirements for e-visits?
- The patient must be established with the practice.
- The patient initiates contact through a patient portal.
- The patient must consent to the e-visit.
- Once the communication is received, the time spent reviewing, assessing, and responding over the next seven days is used to determine the level of service. Time must be documented, along with detailed documentation of the service provided. Documentation must justify the amount of time spent.
What constitutes a patient portal?
A patient portal is a secure online website that gives patients convenient, 24-hour access to personal health information from anywhere with an Internet connection.
Can e-visits be done weekly?
The e-visit is cumulative over a seven-day period. For another seven-day period to begin, the patient must initiate a new communication through the portal.
What does Medicare pay for these codes?
Use the Fee Schedule Look up Tool on the CMS website to find rates for your locality
Topic 3: Essential Healthcare Personnel
The next topic generating confusion is related to therapy’s role as essential. One useful reference for this consideration has been developed by the American Health Care Association.
Personally, I find the following guidance from the above link logical and particularly useful for reference.
Therapy-specific changes that may include the following steps:
1. Review the care plan and its goals and discuss with the resident if the current rehabilitation plan needs to continue or be modified.
a. Some therapy plans of care can be suspended or modified focusing on essential needs, which may vary depending on the current situation in the center or with individual residents.
b. This should evaluate which, if any, specialized rehabilitative services are essential to meet the resident’s health care needs at this time, and which should be deferred.
NOTE: If COVID-19 begins to spread in your facility and staffing levels drop, therapy professionals in a LTC facility should anticipate being asked to provide additional public health support activities within the center and therapy services may need to be suspended in order to meet other residents’ basic needs.
2. Group and concurrent therapy should be discontinued, if part of the care plan.
3. Consider delivering care in individual resident rooms rather than in therapy gyms, and individualized one-on-one care should be provided in a manner to maintain social distancing as practicable.
4. Extra care should be taken following CDC guidance when cleaning therapy equipment between use.
In closing, I hope these resources, which may be “outdated” by week’s end, will provide you a starting point.
We are in this together. Let us stay healthy. Let us stay informed. And let us continue to provide the best of care to those we serve.
American Healthcare Association (AHCA)
American Occupational Therapy Association (AOTA)
American Physical Therapy Association (APTA)
American Speech Language Hearing Association (ASHA)
Center for Disease Control and Prevention (CDC)
Renee Kinder, MS, CCC-SLP, RAC-CT, is Vice President of Clinical Services for Broad River Rehab and a 2019 APEX Award of Excellence winner in the Writing–Regular Departments & Columns category. Additionally, she serves as Gerontology Professional Development Manager for the American Speech Language Hearing Association’s (ASHA) gerontology special interest group, is a member of the University of Kentucky College of Medicine community faculty, and is an advisor to the American Medical Association’s Relative Value Update Committee (RUC) Health Care Professionals Advisory Committee (HCPAC).