During the COVID-19 pandemic, CMS has relaxed its rules for billing Physical/Occupational/Speech with a telehealth codes that Medicare will reimburse at 100%.
|96171||Hlth bhv event fam w/o pet ear||Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20|
|97110||Therapeutic exercises||Temporary Addition for the PHE for the COVID-19 Pandemic|
|97112||Neuromuscular reeducation||Temporary Addition for the PHE for the COVID-19 Pandemic|
|97116||Gait training therapy||Temporary Addition for the PHE for the COVID-19 Pandemic|
|97150||Group therapeutic procedures||Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20|
|97151||Bhv id assmt by pays/qhp||Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20|
|97152||Bhv id suprt assmt by 1 tech||Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20|
|97153||Adaptive behavior tx by tech||Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20|
|97154||Grp adapt bhv tx by tech||Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20|
|97155||Adapt behavior tx phys/qhp||Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20|
|97156||Fam adapt bhv tx gdn phy/qhp||Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20|
|97157||Mult fam adapt bhv tx gdn||Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20|
|97158||Grp adapt bhv tx by phy/qhp||Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20|
|97161||Pt eval low complex 20 min||Temporary Addition for the PHE for the COVID-19 Pandemic|
|97162||Pt eval mod complex 30 min||Temporary Addition for the PHE for the COVID-19 Pandemic|
|97163||Pt eval high complex 45 min||Temporary Addition for the PHE for the COVID-19 Pandemic|
|97164||Pt re-eval est plan care||Temporary Addition for the PHE for the COVID-19 Pandemic|
|97165||Ot eval low complex 30 min||Temporary Addition for the PHE for the COVID-19 Pandemic|
|97166||Ot eval mod complex 45 min||Temporary Addition for the PHE for the COVID-19 Pandemic|
|97167||Ot eval high complex 60 min||Temporary Addition for the PHE for the COVID-19 Pandemic|
|97168||Ot re-eval est plan care||Temporary Addition for the PHE for the COVID-19 Pandemic|
|97530||Therapeutic activities||Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20|
|97535||Self-care mngment training||Temporary Addition for the PHE for the COVID-19 Pandemic|
|97542||Wheelchair mngment training||Temporary Addition for the PHE for the COVID-19 Pandemic—Added 4/30/20|
|97750||Physical performance test||Temporary Addition for the PHE for the COVID-19 Pandemic|
|97755||Assistive technology assess||Temporary Addition for the PHE for the COVID-19 Pandemic|
|97760||Orthotic mgmt&traing 1st enc||Temporary Addition for the PHE for the COVID-19 Pandemic|
|97761||Prosthetic traing 1st enc||Temporary Addition for the PHE for the COVID-19 Pandemic|
(“CMS Table,” 2020, table 1)
This change is retroactive back to March 1, 2020 and applies until the end of the emergency declaration.
Other Points of Interest
|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.|
(Choda,2020, table 1)
It is recommended that you update your website, do email broadcasts, text messages and call patients to let them know that telehealth and e-visits are currently available to them. This will help you initiate these visits.
Medicare E-Visit Guidelines
A patient must request these services, which you will want to document. You will also want to document the services you render. These services may be intermittent over a seven-day period. These service components need to be documented each time they occur. Once you respond to a patient’s request for an E-visit, the seven-day time period begins and ends after seven consecutive days (including weekends, it appears). Only one code can be billed for this seven-day period. After the first seven-day period has expired, a new period begins, and a new charge can be made. You will want to bill the code that best represents the cumulative minutes spent with this patient during the seven-day period. Medicare e-visits can be billed using these coding guidelines:
G2061 – non-physician professional online assessment for established patient, up to seven days, cumulative time 5-10 minutes, Medicare allowed reimbursement $12.01
G2062 – Same as above 11-20 minutes, Medicare allowed reimbursement $21.16
G2063 – Same as above 21 or more minutes, Medicare allowed reimbursement $33.17
G2010 – Remote evaluation of recorded video and/or images submitted by an established patient (i.e., stored and forwarded), including interpreting the images. Must have follow-up with the patient within 24 business hours. Must not originate from a related E/M service provided within the previous 7 days. Must not lead to an E/M service or procedure within 24 hours or the soonest available appointment
G2012 – Virtual check-in by a physician or other qualified health care professional who can report E/M services. Must be provided to an established patient. Must not originate from related E/M service within the previous 7 days. Must not lead to an E/M service or procedure within 24 hours or the soonest available appoint; 5-10 minutes of medical discussion.
These should be billed with the GP modifier, as well as the CR (catastrophe/disaster related) code for these services. Medicare will pay 80% of the allowed amount for these HCPCS codes. It is recommended you check with your Medicare MAC to determine the actual reimbursement before providing these services to be billed.
For asynchronous telecommunications, the GQ modifier should be used. When providing synchronous telehealth services via real-time interactive audio and video you should use the GT modifier. Note that commercial payers may require the POS 02 instead of 11 in these cases. Modifier 95 should be used when synchronous telemedicine services are rendered via real-time interactive audio and video telecommunications systems. However, some commercial payers have said that they do not want to see either the GT or the 95-modifier used.
Flexibility for Provider Enrollment
CMS is providing the following changes during this time:
Medicaid has started to relax their stance on telehealth payments; however, these guidelines vary widely from state to state. Although the telehealth coverage has been expanded, it is advisable to monitor your state’s Medicaid website for coverage guidelines.
Commercial Payers E-Visits
For commercial payers such as Aetna, the following codes can be billed:
98970 – Qualified non-physician professional on-line digital E/M services for an established patient for up to 7 days, for 5-10 minutes
98971 – Same as above; 11-20 minutes
98972 – Same as above; 21+ minutes
Good questions to ask specific payers to determine what you can bill for physical therapy through them are:
Twenty-plus payers have published guidelines for what they will pay. These include, but are not exclusive to, UHC, Aetna, BCBS (varies by state), TriWest, etc.
You can use many platforms, however, here at TotalMD, we use Backline with our providers. This is a very cost-effective, easily set up solution to Telehealth.
If you have questions regarding this information, the following are good resources, or give the Training Department a call at 1-800-613-7597 Option 3.
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
Choda, N. (2020). A Financial Relief Plan & Telehealth Guidance to Reduce your Burden and Help Combat COVID-19. Retrieved from https://intouchemr.com/crisis-management/?__s=x7xreq0tn00qyjok0x9m
List of Telehealth Services. (2020). Retrieved from https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes