CMS (FINALLY) Clarifies Telehealth and Institutional Providers of Outpatient Therapy

CMS (FINALLY) Clarifies Telehealth and Institutional Providers of Outpatient Therapy

On May 27, 2020, CMS updated the “Frequently Asked Questions to Assist Medicare Providers” document posted on their Coronavirus Waivers webpage and offered the long-awaited clarification regarding institutional providers – SNFs, rehab agencies, hospitals, etc. – and telehealth. Outpatient therapy services furnished via telehealth paid under Medicare Part B can be reported on an institutional claim.

The Q&A is on page 70 of the updated FAQ document:

Question: Can outpatient therapy services that are furnished via telehealth and separately paid under Part B be reported on an institutional claim (e.g., UB-04) during the COVID-19 PHE?

Answer: Yes, outpatient therapy services that are furnished via telehealth, and are separately paid and not included as part of a bundled institutional payment, can be reported on institutional claims with the “-95” modifier applied to the service line.

This includes:

      • Hospital – 12X or 13X (for hospital outpatient therapy services);
      • Skilled Nursing Facility (SNF) – 22X or 23X (SNFs may, in some circumstances, furnish Part B physical therapy (PT)/occupational therapy (OT)/speech-language pathology (SLP) services to their own long-term residents);
      • Critical Access Hospital (CAH) – 85X (CAHs may separately provide and bill for PT, OT, and SLP services on 85X bill type);
      • Comprehensive Outpatient Rehabilitation Facility (CORF) – 75X (CORFs provide ambulatory outpatient PT, OT, SLP services);
      • Outpatient Rehabilitation Facility (ORF) – 74X (ORFs, also known as rehabilitation agencies, provide ambulatory outpatient PT & SLP as well as OT services); and
      • Home Health Agency (HHA) – 34X (agencies may separately provide and bill for outpatient PT/OT/SLP services to persons in their homes only if such patients are not under a home health plan of care).New: 5/27/20

A specific effective date is not indicated here, however given that CMS didn’t indicate a different retroactive date to what was released on April 30 for therapists in private practice, it seems likely this clarification follows the initial waiver and becomes effective as of March 1, 2020.

This is excellent, overdue news for providers and for patients who continue to require skilled therapy interventions amidst the challenges of the COVID-19 pandemic.

Holly Hester

Holly Hester is Casamba’s Senior Vice President of Compliance & Education, as well as the Compliance Officer. She provides regulatory guidance and interpretation, clinical programming and content development, education and training steerage, and compliance support for the company. As a physical therapist for more than 20 years, Holly has multi-venue clinical and management experience, giving her a unique perspective on the integration of compliance and training with therapy service delivery and clinical practice.
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