BREAKING NEWS FROM CMS (May 6, 2020)
New today from a CMS Town Hall call:
- PTAs can provide telehealth services.
- If a PTA works in a private practice, then they can provide services via telehealth as long as the PT is available via telecommunications or otherwise (as long as the state practice act allows it).
Please keep in mind that these allowances are only for the duration of the public health emergency (PHE).
When billing in a private practice, these codes can be provided via telehealth – which is defined as audio+visual: 97110 , 97112, 97116, 97530, 97535, 97542, 97750, 97755, 97760, 97761, 97150. Use the POS code that reflects where it would have been furnished if the PHE was not in place. Also append modifiers GP and 95, indicating the service rendered was performed via telehealth.
(*NOTE: CPT code 97535 does not have to be provided with audio+video. It can be provided via audio only).
- Therapists and therapist assistants working in a Hospital outpatient department can provide services via telehealth as long as if a patient is in their home or other location, then that location is registered by the hospital as a temporary expansion location.
When billing on a UB04 or institutional claim, you may bill the CPT code that reflects the services you provided, and use the CR and DR modifiers. Do not use the 95 modifier, since this allowance for hospitals is not the same as the one allowing PT in PP to provide telehealth.
As far as rehabilitation agencies, SNFs and HHAs providing Part B therapy, please stay tuned. We must continue to advocate that they allow therapists in these sites of service to also deliver therapy services via telehealth.
CARES ACT RELIEF FUNDS (April 15, 2020)
Please find below questions APTA submitted to HHS (underlined) asking for clarification on the CARES Act relief funds being deposited into Medicare providers’ accounts and HHS’ email response back to APTA (in bold). Please note that this clarification DOES NOT constitute formal HHS guidance.
That said, APTA does anticipate/is hopeful that HHS will release additional guidance in the coming days to assist providers in determining compliance with the attestation and clarify the terms and conditions.
Q: What exactly does “currently provides care for individuals with possible or actual cases of COVID-19” mean?
Providers have prepared for this, they have programs in place, they have spent money getting ready to treat patients with possible or actual cases of COVID-19, but don’t know how many patients they will actually or have actually seen who may have possible or actual cases of COVID-19. Everyone is “presumed” to have COVID-19, so how can providers actually know if they’ve treated patients with possible cases of COVID-19? Could this term and condition include treating symptoms of COVID?
A: That was in statute. For HHS purposes, we view any patient as someone with a “possible” case of COVID-19 so it covers the entire provider ecosystem.
Q: The term and condition states that the payment shall reimburse the Recipient only for health care related expenses or lost revenues that are attributable to coronavirus.
Does this mean that businesses who had to close due to COVID-19, either due to state mandated orders or who chose to voluntarily close to prevent the transmission of COVID-19 and lack of insurance coverage for telehealth, are allowed to keep the funds, given the lost revenues attributable to coronavirus?
A: Yes you are 100% correct.
Q: Are we sure that physical therapists are eligible to retain these funds?
A: All facilities and providers that received Medicare fee-for-service (FFS) reimbursements in 2019 are eligible. However, the money is being sent based on TINs [Tax Identification Number] filing information. So since a lot of PTs are employed by hospitals and nursing homes, the reimbursement will go to that hospital and nursing home. Whether that money trickles down to the individual PTs is up to each individual entity’s leadership. For example, some entity might choose to spend it all of it on infrastructure.
Q: Do providers have to pay taxes on these funds that have been deposited into their account?
A: APTA does not have a clear answer on this yet.
HHS Deposits Money Into Some Providers’ Bank Accounts
A $30 billion emergency relief package began rolling out on April 10, making direct deposits into provider and facility accounts based on 2019 Medicare billing.
Many health care providers — including PTs — caring for patients with possible or verified COVID-19 received a welcome surprise when they checked their bank accounts on April 10: an infusion of cash released as part of the most recent CARES Act pandemic relief package. The direct deposits are part of a $100 billion program that provides cash based on a provider’s 2019 Medicare billing, under certain conditions.
Think you qualify and haven’t received any money yet? Hang on, the Department of Health and Human Services says the payments will be released over the coming days.
The $30 billion being released by HHS is part of a $100 billion Public Health Service Emergency Fund for health care providers. The funds are being made available to Medicare-enrolled individual providers and facilities that billed Medicare fee-for-service last year. The new funds are in addition to a recent $51 billion expansion to the Accelerated and Advanced Payment Program. But unlike that program, the money now being distributed doesn’t have to be repaid.
How It Works
The money is being distributed proportionally, based on a provider’s billing record for 2019. HHS decided on who gets what by determining the percentage that each provider’s billing represents in terms of total Medicare payments made last year. An HHS resource explains it this way:
“For example, if total Medicare fee-for-service payments in 2019 were $100, and one physician received $2 in payments from Medicare fee-for-service in 2019, then that physician accounted for 2% of total Medicare fee-for-service payments in 2019. According to this formula, that physician would receive 2% of this $30 billion.”
There are terms and conditions related to who can receive the money — some of which are sure to prompt additional questions that can’t be answered at this time.
A guidance document from HHS states that to qualify for the relief, the provider must currently provide “care for individuals with possible or actual cases of COVID-19,” and must not currently be terminated from participation in Medicare or have billing privileges revoked. APTA has asked for additional guidance from HHS explaining if providers and facilities must be front line providers caring for patients with possible or verified COVID-19 infections, or if the funds can go to any health care provider continuing to deliver services during the public health emergency.
How the Money Can be Used
According to the terms and conditions, payments can be used only to “prevent, prepare for, and respond to coronavirus,” with the payments themselves intended for “only health care related expenses or lost revenues that are attributable to coronavirus.”
There are additional restrictions on use, including using the money for reimbursement of losses “that other sources are obligated to reimburse,” as well as prohibitions on using the money to “advocate or promote gun control,” lobbying, funding of abortions, and a host of other social and political issues.
If You Don’t Qualify
HHS says that the intent behind the $30 billion program was to provide immediate relief and that “CMS has indicated that future rounds of funding from the $100 billion fund will have a more formal application process.” Those future funding efforts could devote at least a part of the relief to “providers that do not typically bill Medicare.”
Informal HHS Response Hints at Broad Availability of Provider Relief Money
In an email exchange with APTA, an HHS representative indicated that virtually any PT who received Medicare fee-for-service reimbursement in 2019 could get the funds, and that businesses closed due to COVID-19 could qualify, too. It’s not formal guidance, but the U.S. Department of Health and Human Services has indicated to APTA that the COVID-19 pandemic relief money now being deposited in providers’ bank accounts may be more widely available than you might think after reading the program’s terms and conditions. In short: Initial informal word from HHS is that nearly all providers who received Medicare fee-for-service reimbursement in 2019 could qualify for the money, and providers who had to or chose to shut down business before HHS released the payments may also be able to get the funds.
The question that APTA has been pursuing centers on language in the terms and conditions of the program, which state that the money is to go to providers that “currently [provide] care for individuals with possible or actual cases of COVID-19.” APTA wanted to know how HHS would interpret “possible or actual cases of COVID-19,” and how the department views providers who aren’t currently open — either because of mandatory shutdowns or their own professional judgment.
In an email response to APTA, an HHS representative indicated that the department is interpreting those terms broadly, believing that “possible or active cases of COVID-19” applies to virtually any provider who treated patients during the pandemic, given the infection’s ability to be carried without symptoms. The representative also told APTA that businesses not currently operating likely would be able to keep any funds they received, given that they likely have lost revenues attributable to the pandemic.
It’s potentially good news, but news that should be regarded with caution. This information doesn’t change the importance of reading the terms and conditions of the program, says Kara Gainer, APTA’s director of regulatory affairs.
“The responses we received from HHS are informal, and we hope to be able to share an official position in the near future,” Gainer said. “It’s also important to remember that the language we asked about is just one part of the terms and conditions around the money. Anyone receiving these funds should pay careful attention to restrictions around how it’s to be used, as well as potential reporting requirements.”
APTA staff will continue to monitor this program and share official guidance as it develops. In the meantime, there are resources for more (if not full) detail. Here are a few:
- FAQ: Public Health and Social Service Emergency Fund
- HHS fact sheet: CARES Act Provider Relief Fund
- Relief Fund Payment Terms and Conditions
ALABAMA MEDICAID ALLOWING PT THROUGH TELEMEDICINE (April 6, 2020)
In response to the Coronavirus Disease 2019 (COVID-19) pandemic, Medicaid is temporarily allowing covered physical therapy to be performed via telemedicine. This allowance should only be used for medically necessary services that can be appropriately delivered in a secure, confidential location. The therapy provider and recipient/caregiver must use an interactive audio/video telecommunications system.
Beginning on April 7, 2020, providers may submit claims for dates of service March 16, 2020, through April 16, 2020. The dates may be extended depending on the length of the emergency. Providers may continue to see error codes on their remittance advices with claims payment during the COVID-19 emergency.
Read more at: https://medicaid.alabama.gov/alert_detail.aspx?ID=13786
BCBS TELEHEALTH COVERAGE CLARIFICATION (April 3, 2020)
Good News for PTs and PTAs in Alabama!
Blue-Cross Blue Shield announced last night that they have amended their Telehealth Guidelines to pay for PT treatments, in addition to evaluations, when provided through telehealth.
A few things to keep in mind:
- Services must be performed with audio AND visual technology.
- Max therapy limits apply to telehealth services just as they would in person.
- All codes should be billed with place of service code 02, indicating the service was provided via telehealth.
- The changes apply to Blue Advantage participating providers as well as Preferred Physical Therapists.
Please be sure to read the full Telehealth Billing Guide for Providers located HERE.
ALAPTA continues to work for its members to locate information about various payers and will continue to post information as it comes in. We have inquiries in to Alabama Medicaid and the Alabama Department of Labor. If you have questions about a particular payer, the best way to find the answer is by contacting the payer, since much of the commercial coverage is dependent on whether the member has telehealth coverage in their benefit package. ALAPTA will do our best to answer any questions you may have.
Ellen R. Strunk, PT, MS
APTA Alabama Payment and Policy Committee
BCBS TELEHEALTH COVERAGE CLARIFICATION (March 31, 2020)
We are aware of the confusion surrounding BCBS telehealth coverage for 97530 and 97535. We are actively working to resolve this with BCBS and will communicate as soon as we hear something.
In the meantime, CMS and the CDC have released guidance on infection control and prevention practices in several practice settings. You can find them here:
- Outpatient Settings
- CDC COVID-19 Information for Healthcare Professionals
- CDC COVID-19 Information for Healthcare Facilities
Thank you and stay well,
Ellen R. Strunk, PT, MS
ALAPTA Payment and Policy Chair
NEW RESOURCE FOR MEMBERS (March 30, 2020)
Ellen Strunk, APTA Alabama Payment & Policy Chair, had the opportunity to participate in a webinar on Thursday evening sponsored by the APTA Private Practice Section. There are 3 members working tirelessly on our behalf to catalog all the information received from insurers and states about telehealth and / or e-visit coverage. Each state’s payment chair has been feeding them information over the last couple of weeks as we gather information about payers, and PPS is offering it to everyone to use.
APTA members, please click here to access this valuable resource.
MAKE YOUR VOICE HEARD TODAY: TELL CMS TO COVER TELEHEALTH SERVICES FURNISHED BY PTs and PTAs UNDER MEDICARE (March 30, 2020)
The CARES Act, signed into law on March 27, 2020, gives broad waiver authority to the Secretary of the U.S. Department of Health and Human Services to waive the restrictions on the types of providers who may provide and bill for telehealth services furnished to Medicare beneficiaries during the COVID-19 emergency period. It is important to note that this legislation, while giving the authority to the HHS Secretary (and thereby CMS) to expand the types of providers eligible to furnish telehealth services under Medicare, does not require the Secretary to take such action.
Therefore, we are encouraging all PTs, PTAs, and students to use this template letter to tell CMS to expand the types of providers eligible to furnish telehealth services under Medicare to include physical therapists and physical therapist assistants during the COVID-19 public health emergency. [Submission instructions are at the top of the letter].
Please remember to:
- Sign your Name
- Add any Personal Stories, if You Have Them
- Remove the Yellow Highlighted Portion at the Top BEFORE Sending
Ellen R. Strunk, PT, MS
ALAPTA Payment and Policy Chair
BCBS TELEHEALTH UPDATE (March 25, 2020)
ALAPTA has heard from BCBS of Alabama, and the news in positive. They have determined that physical therapy telehealth services will be paid for their members seeking services.
What do we know?
- Effective March 1, 2020, members with Alabama Blue and Blue Advantage plans can receive telehealth physical therapy services when delivered by a provider within the BCBS network.
- The waiver is allowed through April 16, 2020 and will be reevaluated at that time.
- The Telehealth PT visits will count as a visit against the member’s max therapy limits, just as they would if delivered in person.
- Member copayments are waived for all identified telehealth services, regardless of whether there is a diagnosis related to COVID-19.
- The Telehealth PT visits must include both audio and visual technology.
- NOTE: This is different than Medicare’s E-visit waiver. E-visits do not require a visual component. They can be billed when communication is made via phone call or email.
- BCBS has posted this telehealth Billing guide for Providers: https://providers.bcbsal.org/portal/documents/10226/306297/Telehealth+Billing+Guide/b92b12c5-585f-471c-5921-72465c49b16f.
What do we NOT know?
- What must be documented.
- ALAPTA recommendation: Document the telehealth visit just as you would an in-person visit. Insure you support the type of service provided, as well as the length of time spent providing each service(s).
- How it should be billed. We do not know whether we will be instructed to use CPT™ codes with a telehealth modifier, or whether we will be given special Telehealth codes to use.
- ALAPTA recommendation: Keep good records so you will know what to bill once the guidelines are released. Keep track of the services using CPT™ codes, and the amount of time spent for each CPT™ as well as the total time spent.
- What you will be paid for the service(s).
- Since we don’t know what codes will be billed, we cannot give you fee schedule allowable charges.
ALABAMA PT & PTA PROGRAM STATEMENTS REGARDING COVID-19 (March 24, 2020)
Visit this page for a list of links and updates from colleges and universities as they make accommodations for the COVID-19 pandemic: www.ptalabama.org/covid-19-updates/alabama-colleges-universities/
TRICARE EAST TELEMEDICINE BENEFIT (March 18, 2020)
If a beneficiary meets all other criteria for a covered service for speech therapy and for continuation of PT/OT, (but not initiation of PT/OT), it is covered using telemedicine, using any coding modifiers as you would for a TRICARE network provider office visit.
E-VISIT WEBINAR SLIDE DECK (March 20, 2020)
Thank you to those who were able to join us last night on the webinar about how to do E-visits. Ellen has reorganized the slide deck with some additional information to hopefully add some clarity based on some of the questions received. Due to technology issues, the recording is not available.
As we stressed during the call, the situation is fluid. This handout is current as of now. Please be on the lookout for additional resources if updates to the regulation are announced. We will provide information as quickly as we can. The slides at the end of the deck provide additional resources for you as well as information on how to advocate for physical therapy services to be allowed through the CONNECT Act.
BCBS OF ALABAMA COVID-19 UPDATE (March 20, 2020)
The BCBS of Alabama PT Advisory Committee met with BCBS representatives this week in an effort to address licensees’ concerns about the impact of the COVID-19 on patient care and continuity of care. They announced that they are “moving forward with coverage for telehealth in regards to limited physical therapy”. They asked PT clinics to not file claims yet. They have not worked out the details, but will be forthcoming with those.
To monitor those developments, check this website regularly:
As always, ALAPTA will post information as soon as we get it.