By John Wallace, WebPT
Remote healthcare is having a breakthrough moment across the nation. For years, the full implementation of telehealth has been stymied by insurance roadblocks and bureaucratic red tape. However, with the arrival of the COVID-19 pandemic, many providers suddenly see telehealth as the most viable way to ensure care continuity and patient safety. As a result, telehealth options are expanding at an unprecedented pace—especially within the rehab therapy space.
As of March 17, 2020, CMS temporarily changed its telehealth requirements to allow qualified non-physician healthcare professionals—including physical therapists, occupational therapists, speech language pathologists, and clinical psychologists—to provide and bill for e-visits during the COVID-19 crisis. (Please note that unlike true telehealth services, e-visits are considered assessment and management only. Rehab therapy providers still are not officially recognized as approved telehealth providers under Medicare.) Other insurance carriers also have expanded telehealth and remote care coverage for physician and non-physician providers alike.
While this is a tremendous step in the right direction for specialties that were previously excluded from remote care delivery, it has been disorienting for many as they work to navigate these rapidly evolving opportunities and the requirements that go along with them.
To effectively leverage remote care to serve their patients and keep their practice solvent, practitioners must have a comprehensive understanding of these changes. This starts with navigating the jungle of telehealth lingo, understanding federal and state legislation, and setting up the right technology to interact with patients remotely.
Areas Of Priority
Understand The Language
One thing that has caused much confusion among providers is the term “telehealth” itself, which is used as a generic catch-all within healthcare circles. As noted above, Medicare does not consider e-visits as telehealth by its standard definition of the term. That said, it’s essential to differentiate between the general concept of telehealth and the specific types of billable virtual care visits.
In its most recent final rule, CMS describes e-visits as “non-face-to-face, patient-initiated digital communications that require clinical decision making that would typically have been provided in the office.”
Understanding what e-visits are—and how they differ from true telehealth services—is crucial, primarily they are the only remote care option rehab therapists currently have under Medicare.
The descriptors for the e-visit billing codes suggest that these codes are intended to cover short-term (up to seven days) assessment and management activities conducted online (or via another digital platform) as well as any associated clinical decision making. The e-visit codes can only be used when:
- The billing provider already has an established relationship with the patient;
- The patient initiates the initial inquiry;
- The communications occur over a period of no more than seven days and;
- The patient verbally consents to receive virtual check-in services.
Outside of Medicare, payers may reimburse for other visit types, including online digital evaluation and management services, telephone services, or telehealth services.
Double-Check State Laws
Each state has its own practice act, and some physical and occupational therapy practice acts don’t include telehealth—which may affect the ability to provide telehealth services (even when a payer covers them or you plan to provide them on a cash-pay basis). So, familiarize yourself with your state’s laws before you incorporate any virtual care services into your practice. Keep in mind that in light of the developing health crisis, regulations are changing rapidly, so staying abreast of the latest updates is crucial.
Do The Research
Payer policy is rarely cut and dried. Now, more than ever, it's important to keep tabs on the constant updates. Some payer websites allow you to subscribe to those updates. If nothing else, be sure to subscribe to CMS updates. Often, when CMS introduces a new policy, other payers quickly follow suit—and we’re seeing that happen with telehealth expansion. Additionally, make sure you’re continually checking in with your major payers to see how they are evolving their coverage rules in response to COVID-19. Ask what types of services they are covering, what (if any) special requirements or stipulations apply, and which CPT codes and modifiers are required to bill for those services.
Use The Right Tech
According to CMS, e-visits should be conducted via online patient portals. An online patient portal is a secure online website that gives patients 24-hour access to personal health information from anywhere with an internet connection. It requires a secure username and password so that patients can securely message their healthcare providers.
However, as of March 17, 2020, the Office for Civil Rights (OCR) is exercising enforcement discretion for the duration of the COVID-19 Public Health Emergency for healthcare professionals who provide “good faith telehealth services” to patients through everyday communication technologies like Skype for Business or Facetime. Still, regardless of these new directives, patient privacy should always be your main priority. To ensure the utmost security, providers should use a HIPAA-compliant platform that will enter into a business association agreement with—even if the agreement is executed at a later date. Options that are low-cost, cloud-based, and user-friendly include Doxy.me and Rapid Response from Bluestream.
Get the Word Out
If you’re introducing e-visit options in your practice, you’ll need to let your patients know. You can do this by:
- making an announcement on your website,
- sharing the news on your practice’s social media pages, and/or
- sending out an email.
There is one major caveat to note: while the provider can notify established patients of their ability to initiate e-visits, the patient must initiate the request for a visit.
What Providers Need to Know
Who is eligible to bill e-visit codes?
At the time of writing, Medicare will reimburse specific qualified non-physician healthcare professionals—including physical therapists, occupational therapists, speech language pathologists, and clinical psychologists—for certain e-visit services. Credentialed assistants—such as physical therapist assistants (PTAs) and occupational therapy assistants (OTAs)—seem to be excluded from the list of practitioners who can conduct and bill for e-visits at this time.
How should I document to support billing these services?
Start by documenting when and how the patient initiated the service, as well as his or her consent to receive virtual check-in services. Include the reason why the patient is unable to attend the visit in-person. Document all assessment, management, and clinical decision-making activities, which may include researching clinical best practices or consulting with other providers. Finally, when using a consumer application to conduct the visit, create a record of your use of the platform by taking screenshots of session times logged.
How can providers advocate for additional telehealth opportunities?
In an ideal world, any non-physician healthcare professional—rehab therapists included—would be able to deliver ongoing remote telehealth services to ensure care continuity despite extraordinary circumstances. Unfortunately, the U.S. telehealth situation is not ideal, and each payer and state has its own regulations and guidelines. This means providing and getting paid for telehealth services still feels like an obstacle course for many practitioners.
The current situation is fluid—and CMS and other payers may eventually allow rehab therapy practitioners to provide true telehealth services in light of COVID-19’s public health implications. No one can forecast how regulations will change over the coming weeks or how new payer policies will be implemented. We’ve already seen numerous adjustments to Medicaid, workers’ compensation, and commercial payer coverage policies.
If you find that your state does not allow you to provide any telehealth services, consider taking this opportunity to advocate for change. Advocacy at the state level will lead to meaningful change at the national level. And there’s never been a better time to make that push. Successfully getting qualified non-physician healthcare professionals classified as full-fledged telehealth providers could mean the difference between clinics staying open and shutting their doors.
About The Author
John Wallace, PT, MS has more than 35 years of experience in private practice orthopedics as well as leadership in health IT, revenue cycle management, billing, acute hospital, acute rehab, home healthcare, and other specialties. He currently serves as the Chief Business Development Officer of Revenue Cycle Management at WebPT. He has been invited to speak at numerous national healthcare events on the topics of payment policy, compliance, practice management, and rehabilitation economics and is a coding and payment policy consultant to several APTA components.