These times are unprecedented, and the rapidly changing healthcare landscape leaves many rehabilitation therapists feeling lost, adrift, and worried about their future. That’s why earlier this week, our internal experts, Dr Heidi Jannenga, PT, DPT, ATC, WebPT Chief Clinical Officer and Co-Founder, John Wallace, PT, MS, WebPT Chief Business Development Officer of Revenue Cycle Management, and Veda Collmer, internal advisor and compliance officer for WebPT, came together to host a webinar on business continuity and telehealth. We received hundreds of questions during our Q&A session – too many to answer! – so we have answered the most frequently asked questions here. Can’t find the answer you’re looking for? Feel free to leave us a comment at the bottom of the page and we will do our best to respond.
Health and security
How do we protect our patients at the clinic and during home visits?
For clinic appointments, follow CDC guidelines for social distancing. This means that each patient should always be at least six feet from any other patient. Therapists should wash their hands and thoroughly disinfect all treatment equipment and surfaces before and after the session. For home care, we recommend limiting the equipment and personal items brought home, washing your hands before and after the session, using a tampon or protective surface when placing bags and floor equipment and / or use an alcohol-based cleaning product. In addition, we encourage therapists and clinic owners to:
- implement a policy to encourage sick leave when therapists or their family members feel sick, and
- take advantage of telehealth wherever possible – if your state allows it and your payers will reimburse it.
How to implement social distancing in the context of rehabilitation in private practice?
Certain practices are already invited to implement social distancing in their clinics; but even if you have not been officially asked yet, it is the best large-scale preventive measure we have. This essentially means minimizing the density of staff and patients in your establishment by:
- reduce the number of concurrent appointments;
- encourage non-clinical staff to work from home;
- keep your patients (and staff members) at least six feet from each other at all times;
- filter your schedule to exclude the most vulnerable patients, and therefore protect them from exposure (for example, any frail and elderly person; immune or respiratory impairment; or with severe comorbidities such as diabetes and obesity);
- prevent visitors from entering the clinic; and
- ask family members of patients to wait outside or in their car, as opposed to waiting areas at the clinic.
When we reopen following social isolation and the quarantine period, will patients have to sign a note stating that they understand there is a continuing risk?
According to our in-house lawyer, therapists are not required to notify at-risk patients unless your state has issued an order to the contrary.
How can I train my staff to safely manage patient visits at this time?
Remind them that therapists are well versed in infection control. In fact, we are the masters! Review your infection control, hand washing and universal health precaution policies (more on those here). Remind them to regularly disinfect equipment and educate patients about the risk of in-person meetings.
What should I do if an employee tests positive or has symptoms associated with COVID-19?
The best practices here are really quite simple:
- The very first thing to do is to review this employee’s schedule with him to determine who he or she was close to, that is, within 6 feet, in the past two weeks.
- Then help the employee get the medical support they need as quickly as possible.
- Finally, send home all employees with whom this person has been in contact and contact all patients who may have been exposed to inform them of the situation.
Just make sure you don’t share identifiable information about your sick employee, as doing so would violate workplace privacy laws. Instead, you could say something like, “I have reason to believe that you have been in contact with someone who has tested positive for COVID-19 or has symptoms.” While there is no immediate cause for alarm, you may need to quarantine yourself while monitoring symptoms in accordance with current CDC guidelines. “
Do you recommend that we wear personal protective equipment (PPE) in the clinic?
the Occupational Safety and Health Administration (OSHA) requires employers to provide a workplace free from hazards likely to cause death or serious bodily harm. Employers should refer to OSHA national and federal standards regarding employers’ obligations to reduce workplace damage. According to OSHA COVID-19 Guidelines on the Department of Labor website, the World Health Organization has determined that COVID-19 poses a low risk to healthcare workers. OSHA standards require employers to provide personal protective equipment (including masks and respirators) to employees exposed to COVID-19. Employers are therefore only required to issue masks if the provider treats a patient with a known case of COVID-19. In other cases, the provider must practice social distancing and other measures (for example, washing hands and cleaning equipment) to reduce the risk of infection.
This may not be very reassuring for the provider who treats potentially asymptomatic patients and potentially exposes their families and other patients. However, PPE is fairly rare at this time, therefore, in accordance with OSHA guidelines, providers may consider wearing PPE only if the patient visibly coughs or sneezes and the session cannot be adjusted to avoid close contact. Continue to take other precautions, such as hand washing and infection control. If no PPE is available, adapt the session to create more distance between the PT and the patient and provide less practical care.
the APTA joined with other health care organizations (such as the American Association of Nurse Practitioners and the American Occupational Therapy Association) to encourage government to:
- provide PPE to all health care providers, and
- definitively communicate which suppliers are given priority in PPE.
Does the Family First Coronavirus Response Act (FFCRA) apply to my practice?
According to the US Department of Labor“The provisions relating to paid sick leave and extended family and medical leave of the FFCRA apply to certain public employers and to private employers of less than 500 employees.” To learn more about the law, how it helps small businesses bear the financial burden of paid vacation, and what exceptions apply, see This article.
If we reduce the working hours of our PT staff, are they eligible for unemployment benefits?
We do not yet have details on how employees will receive federal dollars for unemployment under the recent stimulus bill. Aside from federal relief, unemployment guidelines are dealt with at the state level, so please check with your state.
Should companies compensate employees on leave or laid off for accumulated leave?
When considering layoffs and leaves, the employer must take into account issues related to employee health benefits, unemployment benefits, applicable wages and hours laws, and paid leave rules. Dismissed employees can claim unemployment benefits. The question of whether the employer must pay for the PTO accumulated during a leave depends on the type of leave (for example, a week’s leave versus only a few days) and whether the employee is paid or hourly. Employers should also consider how the leave or layoff will affect employee benefits and whether the employee is eligible for COBRA during the leave. If the employer chooses to pay employees for PTO during a period of leave, these employees may not be eligible for unemployment benefits.
In summary, there is no simple answer to this question. This Resource from the DLA Piper COVID-19 Resource Center provides an excellent summary of the various considerations associated with layoffs and leaves. However, please do not rely solely on Internet publications to decide the best course of action. You should consult an employment lawyer for more information on applicable federal and state laws specific to your business.
Miscellaneous questions of continuity
How can I access the money I need to keep my practice afloat with an extended closure?
Although updates are provided daily, we are still awaiting details from the federal government on the COVID-19 economic stimulus package for individuals and businesses. But we do know that disaster relief loans are available from the US Small Business Administration. If your practice is struggling to make ends meet during this pandemic, you can apply for a long-term, low-interest loan Disaster Loans Page from the Small Business Administration website. Small businesses can borrow up to $ 2 million for economic harm. The SBA is also committed to helping small businesses “access federal resources and navigate their preparedness plans”. For more information, visit the SBA site.
Are outpatient home visits covered for SLP? Can any outpatient PT or OT provide home care services to any patient?
Medicare covers outpatient home visits for SLP, OT and PT – but not all commercial payers do. You will need to check with your individual commercial payers to learn more about your coverage.
Keep in mind that Medicare has implemented certain reimbursements for ambulatory health care at home: only pay if the patient is “Not to be confined to the home or otherwise not to receive services under a home health care plan (POC).” In other words, Medicare will only pay for ambulatory home care if the patient is not actively receiving Medicare Part A services.
Foundations and best practices
What are the best practices in telehealth?
The first thing you will need to do is educate your patients, as telehealth rehabilitation is probably not something they have experienced before. Discuss their concerns and explore whether it makes sense to serve them via telehealth. You will also want to make sure that telehealth is within your scope of professional practice in your state and that the majority of your payers cover it (if you plan to receive reimbursement through insurance). If you determine that a large portion of your patients would like to receive care in this way, then you will need to find a compliant platform – ideally one that will enter into a Commercial Associate Agreement (BAA) – and train staff and patients on how to use it.
How should we train our staff in telehealth?
This CMS telehealth toolbox has excellent resources to configure your telehealth environment. We recommend that you organize a few training sessions for your staff to help them plan their telehealth visits and get used to your platform. PT, OT and SLP are highly adaptable; they should quickly take charge with your support. Need inspiration? Check-out this blog post at a New Jersey clinic that quickly implemented telehealth in response to the pandemic.
Is it possible to offer telehealth if you are not using an EMR?
Yes; you would simply need to do all of your documentation by hand. For example, if you provided an electronic tour, you should record:
- how the patient initiated the service,
- that the patient has consented to receive these services,
- all of your interactions with patients, and
- any additional activities you have undertaken to contribute to the referral you have provided to the patient.
That said, we still recommend using an EMR, if your practice environment allows.
Can I provide services that are generally convenient via telehealth?
No; you cannot provide convenient services by videoconference, as there would be no way to do so. Instead, think about other services you could provide to support this patient in their care.
Can we do initial or new telehealth assessments – or should they be done face to face at the clinic?
Currently, there are no specific codes that would allow you to bill for assessment services provided via telehealth. That being said, some states require that any service normally provided in the clinic be covered when provided via telehealth – provided that you can provide the service via telehealth. So be sure to check with your state council as well as your individual payers.
If you are sending pre-recorded videos, is it synchronous or asynchronous?
Sending pre-recorded videos can be technically synchronous or asynchronous depending on how you choose to do it. If you and a patient are having a live conversation and send a link to a prerecorded video, it would be synchronous (or synchronized) telehealth. However, if you and a patient communicate over a long period of time (ie, you are not online at the same time) and you send a prerecorded video to him, then that would be asynchronous (or out of – sync) telehealth.
Scope of practice
How do I know if telehealth is within my scope of practice?
If you have questions about your state practice law or your scope of practice, contact your state licensing board, as this will be your best source. If you have trouble getting through, try contacting your APTA, AOTA or ASHA chapter.
My State Practice Law does not mention “telehealth” or “electronic visits”. Can I provide any type of telehealth service?
In general, if your state practice law does not include language regarding a specific procedure or protocol (in this case, telehealth), you should contact your state licensing office to inquire about its position. Regarding Medicare billing for electronic visits, keep in mind that because these services are not technically telehealth, you can provide them even if your state practice law is silent on the telehealth.
Will California PT practices be able to administer telehealth services to their patients?
Although PT telehealth is permitted by the laws of California (Cal. BCP 2290.5), MediCal (California Medicaid service) does not reimburse this method of service delivery – and commercial payers may also not reimburse. Check your policies for reimbursement guidelines and balance billing requirements to determine if the patient can pay cash for services.
How can I contact my state officials to advocate for further expansion of telehealth opportunities for PTs, OTs and SLPs?
Do you have a verbiage that we can use to advocate the expansion of telehealth?
APTA has created a template that you can access here.
Where can I find APTA telehealth updates?
What other advocacy opportunities are available to me?
Jannenga covered the telehealth advocacy in detail in this recent blog post. Don’t forget to check it out!
How do I document electronic visits and other virtual care services?
Your documentation for these services should emphasize:
- patient concerns and questions;
- clinical assessment and decision making;
- advice, instructions or counseling to the patient, and
- plan the patient’s progress.
For a more detailed explanation on how to document electronic tours, please refer to this FAQ.
Is there a way for a PT to establish a relationship with a new patient who does not want to come to the clinic for an in-person assessment?
According to APTA, the answer is no: “The patient must already be taken care of by the therapist. Check your state practice law for additional advice on what is considered an “established patient”. “
Do electronic visits apply to the Medicare processing threshold?
For the moment, CMS has not specifically addressed this subject. However, therapists are currently not required to add the GP, GO or GN modifiers to the electronic visit services, so it is possible that they are not taken into account in the threshold.
Do electronic visits count towards the patient visit limit and / or do they count?
According to APTA, electronic visits are not taken into account in the number of visits by a patient for the purposes of the progress note. The association also does not believe that electronic visits count “against the number of visits authorized by Medicare coverage rules”.
Can we charge more than one G-code unit over a seven-day period?
No. You should only charge one unit for one code based on the cumulative time you have spent providing the applicable patient services.
What is an example of an electronic visit (for example, file review, home exercise updates, and other activities outside of patient interaction)?
An electronic visit includes evaluation and management time which is generally used to:
- respond to a patient’s concerns about function, pain or a change in status, or
- answer questions about the patient’s HEP or other personal care and home management.
When counting electronic visit time, you can also include the time you spent visiting a doctor or other provider, as well as the time you spent gathering information about the patient’s request or concern.
Should electronic visits take place during a video call or can they take place over the phone?
Electronic visits can take place via interactive video or by telephone. With respect to telehealth services, some states only allow and / or reimburse live interactive video. Some states, such as Massachusetts and Connecticut, have issued decrees extending telehealth to cover audio in addition to video.
Electronic visits are not synonymous with video visits. However, if you use video, make sure that your platform is not accessible to the public or accessible to the public. (That said, regulations regarding approved platforms have been relaxed to allow better access to care.) In general, electronic visits include the following:
- The patient has a concern, question, change of function, or other challenge with care.
- You assess what the patient is telling you and use your clinical reasoning and decision-making ability to create a plan for the patient to move forward. (For example, if the patient tells you that he is able to easily complete his current HEP, you can adjust the HEP to be more difficult, and then send the new HEP to the patient.)
- You document all of these activities and bill the cumulative time you spent on these activities over a period of seven days.
Can we make electronic visits by e-mail?
As far as we can judge, APTA and CMS have suggested that secure email communications would be an acceptable method of conducting electronic visits. However, we warn suppliers who plan to make electronic visits by e-mail: not only will these visits be asynchronous, but also – unless your e-mail is encrypted and complies with HIPAA standards – you risk d ” expose protected health information (PHI) that you include in your messages. Instead, we recommend using a secure platform with real-time communication such as WebPT HEP.
What is the definition of an “established patient”?
As we explained here, with regard to electronic visits. “APTA recommends check your state practice law to see how it defines “established patient.” Typically, these codes are only available to patients who are currently supported by the billing provider. That being said, some definitions may include any patient who has been seen in your practice.
If someone comes to my clinic for a physical visit, can they make an e-visit the same week?
No. According to APTA“An electronic visit cannot be billed if an in-person visit takes place within seven days before or within seven days of the electronic visit.”
Can we reassess via an e-visit?
No. Re-assessments are not part of the assessment and management services that therapists can provide via an electronic visit.
How is the billing period of seven days for the electronic visit defined?
The seven-day period begins when the provider responds to the patient’s initial request.
I work with the elderly and their most advanced technology is the telephone. If I call them for an electronic visit, should I have them remembered so that the meeting is “patient initiated”? Or is it enough for them to say that they want to participate in e-vist?
We recommend using – and clearly documenting your use – very specific verbiage indicating that the patient wishes to initiate an electronic visit. For example, if you call the patient to inform them of this option and the patient requests to participate in an electronic visit immediately, say something like, “Do you want to start an electronic visit?” In addition, Medicare has indicated that electronic visits by telephone are permitted during the COVID-19 response period.
Once a patient has been seen for an electronic visit, do you have to see him in person before you can make another electronic visit?
We think not. However, APTA is seeking clarification from CMS regarding the use of multiple electronic visit codes for multiple periods of seven consecutive (or non-consecutive) days.
What is the difference between managing electronic visit care and education that would normally be a therapeutic exercise? I always refine HEP and count this time to get there; how is it different to discuss the same subject via a patient initiated telephone call?
There is not much – if any – difference between these two actions. Whether you take this into account in your minutes in person or provide these services remotely via electronic visits, you always charge for your assessment and management of a patient’s care as well as your clinical reasoning.
What is the difference between telehealth, telehealth visits, telephone visits and electronic visits?
When we talk about telehealth, we are referring to all of the remote services that clinicians across the healthcare spectrum provide to their patients. Telemedicine is telehealth and telerehab is telehealth. It is important not to confuse telehealth as a general concept with specific types of virtual care visits:
- Telehealth visit: when you treat a patient remotely (for example, by providing virtual treatment).
- Telephone visit: when you communicate remotely with your patients and complete the assessment and case management.
- Electronic visits: when you perform assessment and case management services and specifically bill Medicare – or other payers who now allow rehabilitation therapists to bill these codes.
What are the differences between the place of service (POS) codes 02, 11 and 12?
POS 02 indicates that the “site” of a service is a telehealth interaction. In general, you should use POS 02 if you are providing actual telehealth services via a true synchronous telehealth platform – and not all commercial payers cover these services for rehabilitation therapists. So make sure you are up to date on payment policies before providing and billing telehealth services. Now, if you charge for one of the Medicare electronic visit codes, you will need to use 11 for your point of sale to indicate that you are providing the service from an office, or 12 to indicate that you are providing the service from home. you. Points of sale 11 and 12 also apply to telephone visits.
Which CPT codes should I use to bill for virtual care services?
During this crisis response time, use G2061, G2062 or G2063 to bill Medicare for electronic visit services. These are the only virtual care services Medicare currently reimburses for rehabilitation therapists. If you are billing a commercial payer, you will generally use CPT codes 98970, 98971 and 98972 to bill these services, as these are the CPT equivalents of the HCPCS e-visit G codes. However, we strongly recommend that you contact each payer to verify their guidelines for billing for distance care. Keep in mind that although there are other codes for telephone services (for example, 98966–98968), due to the relaxed requirements around codes 98970–98972, you can also use these codes for telephone services for the time being.
Finally, in a handful of states, you may be able to charge standard rehabilitation therapy CPT codes (for example, 9700 series codes) with the appropriate modifier and POS code. However, you should definitely check with your state council before proceeding.
What is the difference between Medicare G codes for electronic visits (for example, G2061 – G2063) and online digital I / O codes (for example, 98970–98972)?
G2061, G2062 and G2063 are the HCPCS equivalents of the CPT E / M codes (98970–98972). Therefore:
- use G2061 – G2063 when billing Medicare (or any payer following CMS guidelines on electronic visits); and
- use 98970–98972 to bill commercial payers and workers’ compensation payers who do not use CMS codes.
What modifiers should I use to bill for telehealth and virtual care services?
There are four telehealth modifiers that therapists should be aware of before billing for telehealth services. It is essential that therapists understand how these modifiers differ, since each one only applies in certain situations. In other words, you cannot affix a telehealth modifier to a CPT code and bill it as a telehealth service. You must ensure that you always follow the telehealth compliance protocol. This means using specific CPT telehealth codes – or electronic visit HCPCSs – and affixing the correct modifiers, if necessary.
The first telehealth modifier is 95. Use this modifier when administering synchronous real-time services for telephone CPT codes. To be clear, CMS electronic visit codes do not require the modifier 95.
Le deuxième modificateur de télésanté est GT — et il est également utilisé pour indiquer que vous avez fourni des services synchrones en temps réel. Cependant, le modificateur 95 a remplacé GT en 2017, et bien que vous puissiez toujours facturer techniquement GT dans certains cas, le modificateur 95 sera probablement le choix le plus approprié. Certains payeurs commerciaux continuent d’utiliser GT pour les services de télésanté couverts, vous devez donc vous renseigner auprès de vos payeurs individuels pour déterminer le modificateur qu’ils préfèrent utiliser.
Le troisième modificateur de télésanté est GQ. Il indique que les services ont été fournis de manière asynchrone. La télésanté asynchrone est progressivement supprimée et remplacée par la télésanté synchrone, ce qui fait de GQ un «ancien» modificateur, quoique fonctionnel.
Le dernier modificateur, CR, indique que les services sont liés à une catastrophe ou à une catastrophe conformément à la dérogation formelle de 1135 émise par la CMS pour la pandémie de COVID-19. Les thérapeutes en réadaptation doivent utiliser ce modificateur lors de la facturation des codes de visite électronique que Medicare a récemment mis à la disposition des thérapeutes en réadaptation, que les services soient fournis de manière synchrone ou asynchrone.
Puis-je facturer des codes face-à-face normaux avec des numéros de point de vente de télésanté et des modificateurs?
Comme Wallace l’a mentionné lors du webinaire, il ne connaissait qu’une poignée de payeurs qui le permettaient. Pour être clair, vous ne pouvez pas utiliser cette méthode de facturation avec Medicare, et la plupart des autres payeurs n’autorisent pas la facturation des codes de contact personnels directs en tant que télésanté. En outre, il est important de vérifier ce que dit votre loi sur la pratique des États en la matière, car vous ne pouvez pas toujours compter sur vos payeurs pour obtenir des informations à jour sur les lois sur la pratique des États.
Pouvez-vous expliquer la différence entre les sites (par exemple, d’origine et la distance) et le lieu de service?
Le site d’origine est l’emplacement du patient; le site distant est l’emplacement du fournisseur. Le lieu de service est le même que le site distant (c’est-à-dire l’emplacement du fournisseur), mais il est partagé via un code. Si vous facturez des codes CPT pour des visites de télésanté, assurez-vous de désigner le lieu de service (ou POS) comme 02. Si vous facturez l’un des codes de visite électronique de Medicare, alors vous voudrez utiliser 11 pour votre POS pour indiquer que vous fournissez le service à partir d’un bureau, ou 12 pour indiquer que vous fournissez le service à partir de votre domicile. Les points de vente 11 et 12 s’appliquent également aux visites téléphoniques.
Les établissements d’hospitalisation peuvent-ils facturer Medicare Part A (c’est-à-dire sur un UB04) pour les visites électroniques?
Yes. Utilisez le code de condition DR et le modificateur CR dans le format de facturation Institutional 837, ainsi que les codes de revenus appropriés pour PT, OT et SLP.
Si j’organise une session d’instructions en ligne pour un groupe, puis-je utiliser l’un de ces codes pour le facturer?
Cela dépend de la politique du payeur, mais en règle générale – et en ce qui concerne Medicare – ces codes ne sont pas destinés à un usage collectif.
Est-ce que nous facturons aux patients les mêmes taux de quote-part, de franchise et de coassurance pour les services de télésanté que pour les services en personne?
Cela dépend également du payeur. Lors de la facturation de Medicare pour les codes de visite électronique, selon this CMS information sheet“Co-insurance and the Medicare deductible would generally apply to these services.”
Pouvons-nous renoncer aux copays pour la télésanté dès maintenant?
Oui; Le 17 mars 2020, le Bureau de l’inspecteur général a annoncé qu’en raison de COVID-19, les fournisseurs pourraient temporairement décider de renoncer au partage des coûts (par exemple, les copaiements ou la coassurance) pour les services de télésanté sans sanction ni pénalité.
Les PT peuvent-ils facturer une visite de télésanté en complément d’un médecin?
Si vous pratiquez un incident avec un médecin, vous ne pouvez pas facturer le même jour que le médecin facture certains codes désignés. Si vous travaillez pour un médecin dans un cadre de la partie B et que vous utilisez toujours votre propre NPI, vous pouvez facturer les codes de visite électronique le même jour, indépendamment de ce que le médecin facture.
Pouvons-nous fournir – et facturer Medicare pour – des visites électroniques, puis facturer le même patient directement pour d’autres services de télésanté fournis en même temps?
Ça dépend. Comme pour les services en clinique, si les autres services sont généralement couverts par Medicare, vous ne pourrez pas accepter les paiements directs pour eux. Nous vous recommandons de contacter votre MAC pour confirmer les services pour lesquels vous pouvez facturer les patients directement.
Couverture et remboursement
Quels sont les taux de remboursement de la télésanté de Medicare?
Pour le moment, Medicare ne remboursera pas du tout les PT, OT ou SLP pour les visites de télésanté ou les visites téléphoniques. Medicare ne paie que des thérapeutes en réadaptation pour des visites électroniques, ce qui …selon cet outil de recherche de barème de frais CMS—Les moyennes de remboursement actuelles sont de:
- G2061: $ 12.27
- G2062: $ 21.65
- G2063: $ 33.92
Dans quelle mesure est-il possible que nous puissions facturer (et être payés) des services de télésanté pour tout payeur dans un avenir proche?
Tout change rapidement, ce qui signifie que tout est dans le domaine du possible. Surveillez les mises à jour de CMS, de l’APTA, de vos payeurs locaux et bien sûr de WebPT.
Dois-je contacter individuellement chaque payeur pour vérifier la couverture de télésanté?
Oui, car la couverture des transporteurs commerciaux peut varier.
Si le plan de soins d’un patient a expiré, pouvez-vous continuer à facturer les visites électroniques?
Nous recommandons de mettre à jour le plan de soins pour intégrer le besoin de soins continus.
Quelles assurances couvrent les visites électroniques?
Medicare a été le premier payeur à couvrir les visites électroniques, mais certains autres payeurs commerciaux emboîtent le pas (par exemple, Aetna, certains plans locaux du BCBS). Vous devez vous renseigner auprès de vos payeurs pour déterminer s’ils couvriront ou non ces nouveaux codes de visite électronique.
L’ensemble des travailleurs couvre-t-il la télésanté?
Ça dépend. Pour tous les traitements associés à l’indemnisation des accidents du travail, il est préférable d’obtenir une préautorisation. De cette façon, vous saurez si vos services sont couverts ou non avant de les fournir.
Medicaid rembourse-t-elle les visites de télésanté, les visites téléphoniques ou les visites électroniques – et où puis-je rechercher les informations pour mon état?
Are patients able to do self-pay for telehealth visits and circumvent their insurance at this time?
That depends on the contractual relationship you have with the payer and its rules for collecting payment directly from patients.
How do I create a cash-based telehealth fee schedule?
Just as with in-clinic cash-pay services, you’ll have to determine the market value of your services and price accordingly. To establish a baseline, consider reaching out to other providers in your region to determine what they’re charging and/or what insurance companies are paying.
If you provide a superbill to cash-pay patients and they submit it to their insurance company, will they get reimbursed at an out-of-network rate?
That depends on the relationship that you have with that payer and its coverage of telehealth services.
Is there any scenario in which you can’t collect cash payments from patients?
Oui; if a payer’s medical policy classifies telehealth therapy services as “not medically necessary” or says that “its effectiveness is not established,” then you cannot balance bill the patient. If you do end up charging the patient and sending the bill to the payer, then it will assign the balance to the clinic or to the therapist who provided the services.
Can I provide telehealth services beyond e-visits to Medicare patients on a cash-pay basis?
Yes, but you should follow the appropriate advance beneficiary notice of noncoverage (ABN) protocol. Learn more about ABN here.
Disclaimers and Consent Forms
Does an established patient need to sign a telehealth consent form prior to every session?
According to Collmer, some states explicitly require providers to obtain patient consent prior to delivering any telehealth. However, obtaining consent is always a good idea. So, consider providing your staff with a template to read when initiating a telehealth intervention program. This script should explain the risks to privacy and health information security that are unique to this delivery method, emphasize that the patient should feel comfortable with this mode of service delivery before consenting to it, and make clear that the patient can withdraw consent at any time. Additionally, explain that your platform is HIPAA-compliant (if it is, indeed, HIPAA-compliant) and that the therapist will take every possible measure to protect the patient’s privacy. Then, once you’ve received consent, document informed consent at the beginning of your treatment note.
What are our options for patients who are not tech savvy or don’t have access to the technology necessary for telehealth? Could they take a photo of their signed telehealth consent forms and email it to us?
A photo of the signed consent form that you upload into your EMR patient record should suffice; however, patients will still need to be able to use technology to access the videoconference. This shouldn’t be too difficult, but it may take some extra time and instruction to help non-tech savvy patients get used to the new format.
HIPAA Compliance, Liability, and Privacy
How do I set up a HIPAA-safe video interaction?
First, when it comes to choosing a platform, you’d normally have to conduct a comprehensive risk assessment before picking a telehealth software. But, under the current circumstances, the HHS Office for Civil Rights (OCR) is giving providers a little bit of wiggle room. As of March 17, for the duration of the nationwide public COVID-19 health emergency, the OCR is exercising enforcement discretion for healthcare professionals who provide “good faith” telehealth services to patients through everyday communication technologies. In other words, you won’t have to go conduct an entire, thorough comprehensive risk assessment when equipping yourself for telehealth during this crisis, which makes it a little bit easier to get your teleservices off the ground.
If you’re considering this option, OCR specifically recommends platforms like Skype for Business, Facetime, Updox, Vsee, Zoom for Healthcare, Doxy.me, or Google Hangouts. Rapid Response from Bluestream is another option we mentioned during the webinar. That being said, we highly recommend selecting a HIPAA-compliant platform that will enter into a business associate agreement (BAA) with you—even if you do so at a later date.
A consumer-facing platform may fit the bill at this time, but patient privacy should still be a priority—even if it’s not your first or second priority right now. And when you have an opportunity to vet your platforms through a comprehensive risk assessment, we recommend doing so. And please understand that these suggestions are not affiliated or officially endorsed by WebPT.
As for physically administering the visit, we recommend that the provider deliver services from a private location where his or her conversation and the video cannot be observed. Similarly, we recommend that the patient receive services in a private location. Finally, avoid recording the session.
What’s a comprehensive risk assessment?
The HIPAA Security Rule requires Covered Entities to perform a comprehensive risk assessment to protect the confidentiality, integrity, and availability of PHI. In layman’s terms, that means assessing systems that will store, access, or transmit PHI to make sure they have adequate safeguards to protect PHI. According to the US Department of Health and Human Services, there isn’t a single best practice method for conducting a risk analysis, but HHS does say that your risk analysis—however it is conducted—must contain the following steps:
- “Identify and document potential threats and vulnerabilities;
- Assess current security measures;
- Determine the likelihood of threat occurrence;
- Determine the potential impact of threat occurrence;
- Determine the level of risk; and
- Finalize documentation.”
The above-cited resource provides a handy link to a security risk assessment tool you can use. WebPT has also written about strategies for tackling a HIPAA risk assessment and why the HIPAA risk assessment is important.
In the case of performing a HIPAA risk assessment for a telehealth platform, you may consider reviewing the vendor’s security whitepapers and asking for evidence of completion of a security audit (e.g., ISO27001 or SOC 2). Find out how the vendor is protecting PHI on their systems:
- Does it encrypt data?
- Does it audit and monitor its systems?
- Does it have a named information security officer?
- Does it have privacy and security policies in place?
You don’t have to be a security expert, but you are expected to ascertain whether the vendor has reasonable and appropriate safeguards in place.
What about telehealth liability issues? Do I need my own liability insurance for this, or will my employer cover any possible issues?
Telehealth liability concerns may include such issues as medical malpractice, lack of informed consent, and privacy or security breaches. Employers and independent contractors should check with their insurance carrier or insurance broker to ensure they have appropriate coverage for providing telehealth services. Insurance coverage may include malpractice, cyber liability, and general liability coverage. Employees should check first with their employer to make sure they are covered under the company malpractice insurance policy. If necessary, you can purchase additional malpractice insurance through such carriers as HPSO, although you should confirm that the policy covers liability related to telehealth.
If you provide telephone visits from home, how do you keep your phone number private from patients?
You can use a calling service such as Google Voice, which gives you an alternate phone number to use for these interactions. You may also be able to block your phone number through your telephone provider; however, you’ll need to let your patients know that you are calling from a blocked number to ensure they answer the call. Alternatively, your company may be able to route office numbers to staff cell phones. That way, a patient could call your office number and be routed to your personal cell phone for the duration of this crisis.
Miscellaneous Telehealth Questions
Will physician referrals need to specifically state “telehealth” on the order, or will a standard order for an eval and treatment suffice?
Physician referrals may need to specifically state telehealth; it will depend on the payer and direct access rules and regulations in your state.
We’ve been told that different payers sometimes maintain different telehealth vendor requirements. Could I use a different vendor for each patient I see?
This could quickly become quite expensive, but theoretically, yes.
If we are able to provide telephone or e-visit services, who initiates the call? Do the patients have to be the ones to call?
The patient must be the one to request the visit, but he or she doesn’t necessarily have to initiate the call. However, providers are allowed to notify patients of the availability of the services and the requirement that they must be patient-initiated.
How can I offer telehealth to patients who are working on board a ship in international waters?
State licensure requirements still apply in telehealth situations, so before you start treating patients outside of your state, exercise caution, and contact your state licensing board—or consult with a healthcare law expert—first. Beyond that, if you’re providing rehab therapy under a workers’ compensation plan, get it authorized. If the patient has commercial insurance, contact the payer directly to determine if it will allow you to provide the services.
Is there a limit to how many days per week or number of sessions that we’re allowed to provide patients (and bill) over telehealth?
That depends on the code you are billing. If, as in the case of the e-visit G-codes, the code description indicates that you may bill one code for each seven-day period, then you would count all time spent delivering associated services toward your billing of one code. That one code would cover a period of seven consecutive days (for e-visits, this seven-day period begins when you respond to the patient’s initial request).
Can PTAs and COTAs provide telehealth—and is it reimbursable?
As of right now, physical therapist assistants (PTAs) and occupational therapy assistants (OTAs) cannot provide e-visit services to Medicare beneficiaries. However, many states that have authorized telehealth have included PTAs as authorized providers. Check your state laws or email your state licensing board for more details. Also, check your payer policies to make sure PTA services can be reimbursed.
Assuming PTAs can supply telehealth, how does supervision work?
Your state practice act still dictates supervision rules. If the practice act requires general supervision of a therapist assistant, then the licensed therapist has to be available at minimum by phone; if it requires direct supervision, then the therapist must be in the same building or line of site. Check the practice act for specific definitions. For Medicare beneficiaries, refer to the Medicare guidelines as well as your state practice act and implement the stricter of the two.
Pediatric and School-Based Telehealth
How can I provide telehealth services as a school-based rehab therapy provider?
During the webinar, Wallace recommended checking in with your school or district medical director or program coordinator for guidelines on patient management during this crisis response period. If you get the green light to continue managing patient care, find out whether you should follow CMS guidance or commercial payer guidance. If you are following CMS guidance, bill for these services using the e-visit G-codes. Otherwise, use CPT codes 98970–98972. When treating pediatric patients who are covered by commercial insurance, you should follow the same process you would for adult patients. That is, check in with the payers to determine what their current telehealth policy is—and how rehab therapy providers should bill for remote care services. Finally, keep in mind that many state Medicaid programs already had rehab therapy telehealth coverage prior to the pandemic, so if you’re seeing a Medicaid-covered child, be sure to check in with your state Medicaid program.
What online materials (e.g., worksheets, interactive programs) could I share with my pediatric patient population? Are there any platforms that have customizable content for children? What if I need sensory or tactile resources?
Remember that the e-visits and telephone visits are assessment and management sessions; when billing these codes, you will not be able to supply the entire gamut of hands-on services you deliver in your office setting. Instead, focus on how you can help parents and guardians manage the child’s program from home.
Also, you can email any necessary materials to the patient or caregiver as long as you don’t include PHI in the email. As for interactive programs, check with your professional association, professional trade groups, and peers who may have resources available to share.
Some Medicaid programs and commercial payers reimburse for telehealth services, which are virtual therapy sessions (similar to in-person visits). Here are three sites you may find useful for pediatric telehealth visits:
As for developing sessions that integrate sensory or tactile resources, telehealth will require you to be creative and use resources in the patient’s environment. Those resources can be in the form of people (e.g, teaching the parent how to apply proprioceptive pressure) or equipment (e.g, using a mini trampoline or soft pillows) or materials (e.g., using things like Play-Doh, rice, or finger paints). Telehealth requires some pre-planning, but it also allows you to educate parents about sensory resources available right in their home and thus, facilitate your patient’s use of these resources long after the session is over. Send the parent a list of items—or even a treatment session agenda—in advance so he or she can help set up the environment.
How do I increase parent buy-in if I want to provide telehealth services for pediatric patients? Many parents just say “no”—even though we’ve issued a company statement—because they assume it’s not a good fit for them or their child.
As Collmer explained during the webinar, when speaking with parents, you should focus on the child’s needs. Consistency and continuity of care are critical for the child’s well being. In fact, it is especially critical to maintain these services during this time when families are largely confined to the home, and the child’s schedule may be disrupted by school closures. If social distancing and other measures continue for several months, it could result in significant setbacks for the child. If you’re still experiencing objections, consider asking parents to try out telehealth for a few visits or hop on a video call to discuss their concerns about telehealth. Be sure to explain that this is an excellent opportunity to try a new mode of service delivery, and if it is successful, it may be used in the future when the parent is unable to schedule an in-clinic appointment.
How does all of this relate to school-based PTs? Teachers are not being required to teach our children for 7.5 hours a day; so, are we expected to still follow our IEP service times?
That largely depends on the essential provider rules outlined by your state and the expectations established by your school and school district. We recommend reaching out to your employer to determine requirements in this crisis.
Which telehealth services are compatible with WebPT—and do you plan to add a HIPAA-compliant telehealth service to your system in the future?
The WebPT EMR already has e-visit billing codes and the ability to specify the necessary place of service code for remote services. Additionally, our HEP platform includes the functionality necessary to conduct an e-visit. Any CPT code not already available can easily be added in the custom CPT code fields on the billing section of a SOAP note. If your patient visit requires a virtual, face-to-face interaction, you can use a free, HIPAA-compliant telehealth service like Doxy or Rapid Response from BlueSteam. (Although HIPAA guidelines are relaxed during the national emergency and allow for non-HIPAA compliant services like Facetime or Skype, we recommend finding a long-term solution that will work for your clinic.) We’re also currently investigating additional telehealth updates to our platform.
How do I document telehealth in WebPT?
In the WebPT EMR, e-visit codes are already available in the billing section of a SOAP note, and you can add any CPT codes for telehealth that aren’t already available as custom CPT codes. You can then bill these codes out to your billing software—whether that’s RevFlow, Therabill, or a third-party integrated billing product.
How does WebPT facilitate e-visits?
Our HEP includes functionality that allows patients to download an app and use it to securely communicate with their therapy providers. The app allows patients to initiate the request for an e-visit—which is a requirement for billing—to which the provider can respond appropriately. You can then continue communicating with the patient as necessary—and update the HEP based on those interactions. Finally, you can send updated HEPs directly to patients through the app.
Where in WebPT can I change the POS and site location?
You can update the POS for each individual case within the case itself in the patient chart, or for an individual date of service on the Objective/Billing tab within the SOAP note. This article from the WebPT Community provides step-by-step instructions on how to do this as well as how to ensure every user has the ability to edit the POS.
Have the telehealth billing codes and modifiers that you mentioned during this webinar been uploaded to WebPT?
Oui; however, you may need to manually enter the modifiers into the WebPT EMR. If you’re a WebPT Member, this article from the WebPT Community will walk you through the process of doing so.
We don’t use WebPT at Reach. Is there another platform you would recommend to provide general email updates to our community?
We highly recommend Reach, as it is completely secure. There are other basic email platforms that you can use to reach your community (e.g., Mail Chimp and Constant Contact). Just be sure that you are always blind copying your list and not discussing any protected health information, as these platforms are not HIPAA-compliant. You can learn more about selecting the right email platform for your marketing needs in this free e-book.
Who is considered an essential provider? If we’re considered an essential provider, are we required to continue working despite concerns about our own safety?
Decisions regarding essential providers are determined at the state level.
We have reached out to the payers, but after hours on the phone no one is able to tell us which codes to bill or how to bill (even for payers that say they will cover telehealth). What is the best way to get through to a person who actually knows helpful information?
When reaching out to payers, the first person you speak with will most likely be a Tier 1 support representative who can answer basic questions about claim status and provide general information regarding plan benefits. So, to get to someone who can answer more specific questions, you may need to ask to speak with the person above that support rep. If the next person can’t assist you, you’ll probably have to go above him or her, too. You may need to keep trying until you can speak to someone who can either provide you with that information or direct you to someone who can. Also, remember to make a note of who you speak with whenever you call—as well as what information they gave you. That way, you can place the onus on the payer should you receive conflicting information.
What if the patient has two separate diagnoses and is being treated by two PTs? Can we provide two telehealth visits in the same week?
Medicare’s rules regarding patients with multiple diagnoses remain the same as they are in the clinic: a patient can see more than one PT on different days for separate issues provided that the PTs are part of the same clinic.
How can we set a plan of care duration when we don’t know how long this crisis will last?
Do your best to make an educated guess given the information you have available to you right now. You can reassess as time goes on and we learn more about the expected duration of this crisis.
Didn’t see an answer to your question? Feel free to drop it below, and our team will do its best to give you an answer. Stay safe, be healthy, and best wishes to everyone.