CMS Moves to Allow Digital Communications by PTs
Wednesday, March 18, 2020
Link to story: www.apta.org/PTinMotion/News/2020/03/17/E-VisitsCMSCoronavirus/
Please note that while the announcement allows for PTs to provide “e-visits” it does not add PTs to the list of authorized providers who can provide telehealth services under Medicare.
CMS Moves to Allow Digital Communications by PTs
The new regulatory waivers will allow PTs, OTs, and SLPs to engage in patient-initiated "e-visits" for purposes of assessment and management services.
In the federal government’s rapidly evolving response to the coronavirus pandemic, the U.S. Centers for Medicare and Medicaid Services has announced that it is easing Medicare telehealth restrictions in ways that could allow PTs to provide "e-visits," a limited type of service that must be initiated by the patient. Prior to this change CMS did not recognize PTs among the health care professionals allowed to bill codes associated with the visits.
The change, announced midday on March 17, is part of a set of loosened requirements that CMS has adopted to expand the provision of telehealth and patient-initiated digital communications, such as e-visits, to help blunt the spread of COVID-19. For the most part, PTs remain outside the reach of these so-called "1135 waivers" related to telehealth, with one exception: a type of remote interaction CMS calls an e-visit under Medicare Part B.
In its 2020 physician fee schedule final rule, CMS describes e-visits as “non face-to-face patient-initiated digital communications that require a clinical decision that otherwise typically would have been provided in the office.” The code descriptors suggest the codes are intended to cover short-term (up to seven days) assessments that are conducted online or via some other digital platform, and include any associated clinical decision-making.
Under the waiver guidance issued by CMS, Medicare beneficiaries can qualify for e-visits no matter their geographic region or physical location, meaning that the provisions have been expanded to nonrural areas and can take place with patients in their homes. The big news for PTs and their patients is that, for the first time, PTs will be allowed to bill for e-visits under codes associated with online assessment and management services (codes G2061, G2062, and G2063).
To qualify as an e-visit, three basic qualifications must be met: the billing practice must have an established relationship with the patient, meaning the provider must have an existing provider-patient relationship; the patient must initiate the inquiry for an e-visit and verbally consent to check-in services; and the communications must be limited to a seven-day period through an "online patient portal."
Although the patient must initiate, CMS writes in a fact sheet that "practitioners may educate beneficiaries on the availability of the service prior to patient initiation." For example, if a patient cancels treatment because they can’t come to the clinic or are concerned about leaving home, then the PT may advise the patient that she or her can reach out to the therapists as needed.
Alice Bell, PT, DPT, APTA senior payment specialist, says that the waiver has some very practical implications for PTs, and offers a possible scenario in which the e-visit could be useful.
"Let's say that, as a PT, I've been seeing a patient for an orthopedic condition and I am progressing the patient’s exercises," Bell said. "The patient is unable to come into the clinic but calls me to say she's having difficulty with one of the exercises and that the other two seem to be too easy. I could arrange an e-visit with the patient and discuss her performance of the exercises. And I could then make a determination — maybe I find that the patient is performing one of the exercises incorrectly — and I could direct the patient on the correct performance. Perhaps I also determine that two of the exercises can be progressed because the patient is improving, so I could instruct the patient in the two new exercises. After that I could advise the patient to contact me for a follow-up e-visit as needed until the patient can return to the clinic."
The HHS Office of the Inspector General has also issued a policy statement that provides guidance on how it interprets the new telehealth waivers.
"As we've seen over the past few weeks, and especially during the past few days, we're dealing with an extremely fluid situation in terms of response to the coronavirus pandemic," said Kara Gainer, APTA's director of regulatory affairs. "This waiver and other changes have the potential to make a difference, and we hope that CMS continues to take steps that can help providers and their patients stay healthy."
APTA has issued a statement on patient care and practice management during the COVID-19 outbreak, and offers a webpage to keep members up to date with the latest news on the pandemic. To determine the reimbursement rates for G2061-G2063, please visit theCMS Physician Fee Schedule lookup tool. Note: The Medicare coinsurance and deductible would apply to these services.
Finally: Additional details (FAQs) on the e-visits:
- When it states established patient, does that mean we could put something on our website to state this is currently available or if a patient calls to schedule an appointment, we would notify them of this option then? This is currently available for patients who are already under the care of the therapist.
- If they came in for an in person visit (eval), could they switch to a telehealth visit for the second one? Keep in mind that these are not telehealth visits in the truest sense. This is a means by which a therapist can manage the care of a patient over a 7 day period when the patient is unable to or does not need to come into the clinic.
- What do they mean, for up to 7 days, cumulative time 7 days? We can only do this for up to 7 days for a patient? We can’t do this services for a total of 7 days of cumulative time? The therapist would bill the appropriate code based on the cumulative amount of time spent over a 7 day period.
- Is that 7 day period defined (Sun to Sat?) or is it just from the start of the first telehealth visit and 7 days thereafter? The 7 day visit begins with the initiation of the request for the evisit from the patient and includes reviewing records, consulting with other providers and the actual communication with the patient.
- Does this also mean we only submit this code every 7 days? Yes, the appropriate code would be submitted once every 7 days. Additionally, the patient cannot have been seen for 7 days prior to the e visit or within 7 days after.
- Being seen meaning in the clinic (there is no limit between telehealth visits)? So in the example above, they patient can be seen for the eval then after 7 days have passed be seen for a telehealth service. Then wait 7 more days to be able to come in to the clinic again? Also, is the date of the clinic visit included (Day 1) in the 7 days or is day 1 the day after the in person visit? The 7 days would begin after the visit.