With the COVID-19 outbreak, medical professionals are increasingly relying on telehealth as a way to administer care while staying protected. Government agencies are rapidly adapting to this changing landscape with new policies and procedures. Casamba has created this Telehealth Resource page to help you keep you in the know.
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Can institutional providers (e.g., SNF, hospital outpatient department, rehab agency) provide and bill Medicare Part B for e-visits, virtual check-ins, remote evaluation of recorded video/images, or telephone assessments?
At this time, it is unclear whether all settings can bill for these services. Based on language in the Interim Final Rule, CMS referred to “private practice” PTs, OTs and SLPs as providing and billing these services, but did not explicitly exclude institutional providers. APTA has indicated they are seeking additional clarification from CMS.
Can I provide e-visits or virtual check-ins to patients in a skilled stay in a SNF? What about a home health patient?
From a Medicare perspective, specific reimbursement for communication technology-based services, like e-visits and virtual check-ins, is via the Part B Physician Fee Schedule based on the number of units of specific HCPCS/CPT codes on the claim. Therapy services provided to patients in a Medicare Part A stay in a SNF or to a beneficiary in a home health episode paid under Medicare Part A are not separately billable to Medicare as a line item on the claim. All services provided to a SNF Med A resident or a patient under the care of a HH episode would be covered under the per diem or episodic rate received by the SNF or home health agency.
Are there particular requirements when it comes to the telehealth platform? Do they need to be HIPAA compliant?
For the duration of the national public health emergency (PHE) due to COVID-19, the HHS Office for Civil Rights (OCR) has waived penalties for HIPAA violations against health care providers “that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype.” Therefore, during the PHE, providers have some flexibility as to which method they use to communicate with patients in certain cases, although a HIPAA-compliant platform is always recommended. Check with your MAC and with each payer as to specific requirements regarding available technology.
Can PT/OT/STs provide telehealth under Medicare?
On April 30, 2020, CMS released a new blanket waiver that includes PTs, OTs, and SLPs as eligible providers of telehealth under Medicare Part B. Check with each payer for their requirements.
Can PTAs or OTAs conduct telehealth visits?
It depends on the state practice act and payer requirements. As for e-visits, those can only be conducted by a PT, OT or SLP.
Can PTAs or OTAs conduct e-visits?
No. E-visits can only be conducted by a PT, OT or SLP.
Are e-visits considered Telehealth?
E-visits are not telehealth services, and are not considered “treatment visits.” They are not considered replacements for clinic/in person treatments for Medicare patients. They allow a way for clinicians to “keep in touch with” their patients during this time.
Can more than one e-visit G-code be combined for billing?
No, only one G code can be billed to Medicare Part B for an e-visit based on cumulative time over a 7-day period. For more information on reimbursement, refer to the Medicare Physician Fee Schedule.
Is there a way for a SNF in a continuing care retirement community (CCRC) to use e-visits?
The “rules” for e-visits for Medicare Part B apply to all Medicare Part B beneficiaries, whether coming in to an OP clinic or residing in a CCRC. Note that the patient must initiate the e-visit and consent to it.
Can a clinician conduct an e-visit for an out-of-state patient?
The therapist must be licensed in (or have compact privileges in) the state where both the therapist and the patient are located.