Billing Telehealth During COVID-19 for Physical/Occupational/Speech Therapy 

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

• For the listed telehealth services, Medicare pays the same amount as if the services were provided in person.
• A list of all CPT codes for telehealth services are available on the CMS website:
  https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes

• The Place of Service guidelines are similar to in-person visits, POS would be 11 if the patient was seen an outpatient setting.  Also, just like an in-person visit, the GN, GO or GP modifier is needed.
• During the designated time period, Modifier 95 needs to be applied to all claim lines for services rendered via telehealth.
• Patients may be either established or new.
• Patients locale can be any geographic area, not just rural areas.  These can be provided in any health care facility or at home.
• Services can be rendered from the Provider’s home while continuing to bill from their CMS enrolled address.
• Document, document, document!  It is important to note the type of technology used for treating the patient as well as the patient’s consent to be treated via telehealth.
• Be sure to follow any state-specific, county-specific or contractual guidelines.

Telehealth/E-Visit Definitions

Below are some definitions that will help you determine if you are billing a telehealth or an E-visit:

                                                Telehealth                                                                          E-Visit

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:

• Postponement of all revalidation actions
• Allowing licensed providers (including physical therapists) to bill Medicare for services outside of the state in which they are enrolled
• Expediting any pending or new applications for providers
• Practitioners can render telehealth services from their home without providing Medicare with that address.  They can continue to bill from the address Medicare has on file.
• Allowing opted-out practitioners to change their status to be able to provide care to more patients

Medicaid Payment

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:

• Will physical therapy services be covered as telehealth services?
• If so, what codes and modifiers are to be used?
• What devices and applications can be used?
• What kind of patient consent do you need for these services?
• Is there special documentation required?
• Will they pay only for current patients or new patients as well?  Does it cover evaluation services?
• Will they only pay for in-network providers?
• For out-of-network providers, do the pay that benefit amount?

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.

Telehealth Platforms

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.

Coronavirus 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

References

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