A Round-up of Telehealth Issues in the Era of COVID-19
By Robert Hall, JD, MPAff
During the COVID-19 pandemic, government health authorities have urged the mitigation strategy of “social distancing,” which has a critical public health aim but an outsized impact on physical therapy practices.
This has led many insurers to recognize the value and importance of supporting physical therapy practices by recognizing telehealth as a valid care platform. Many questions have arisen during the pandemic about the loosening of the rules around telehealth practice, billing, and payment, but the crisis has proven that telehealth can, at the very least, supplement private physical therapy practices.
The best-case scenario for coverage of telehealth by payers includes five important elements. First, the codes that must be recognized for payment include the appropriate 97xxx series of codes, not just the G Codes initially used by Medicare and some other payers for e-visits, which are not true telehealth. Second, physical therapists must be explicitly listed as eligible providers. Third, to make billing as clean as possible, Place of Service Code 02 must by included. Fourth, payment must be at least equal to payment that would be received for an in-person, face-to-face visit (check the parity laws in your state). Fifth, PPS would prefer that modifiers be allowed to be used for billing. In regards to the fifth issue, some payers have stated that they will recognize payment with our preferred -95 modifier, but it will be automatic for all payers if the CPT manual is modified to include the 97xxx series of telemedicine codes in Appendix P. We are working hard with APTA to encourage these CPT changes.
Beyond these technical asks, it’s important to also recognize the human cost that the pandemic has had on physical therapy patients. The population that many physical therapists care for is disproportionately older, and these populations have a higher risk of isolation as well as a proven higher risk of mortality from COVID-19 infection. These factors add up to a perfect storm for physical therapy practices that generally depend upon a hands-on approach — especially with seniors. Luckily, the federal government has started to loosen some restrictions on delivering care through the use of telemedicine, but could still go further. As of April 23, 2020, it is unclear if Medicare will open the door fully to telehealth in physical therapy.
That is the patient and government side. But for your private practice, there are many considerations before you decide to turn to telehealth to deliver care. At some time, the pandemic will abate and practices will return to some semblance of normal. If you decide to implement telehealth in your practice, it is important it be done with liability and ethical issues in mind. To provide more flexibility to practices, two federal responses to the pandemic have included an explicit allowance for telehealth to be used by physical therapists. Under a Medicare Part B program, physical therapists may bill codes G2061-G2063 for “e-visits,” and in Medicare Advantage, the Administration allowed for flexibilities for Medicare Advantage private plans to begin loosening restrictions on payment prior to the pandemic. However, in response to the pandemic, Medicaid, the Children’s Health Insurance Program, federal premium and other tax credits [many “Obamacare” plans], and others still do not explicitly allow reimbursement for telehealth by physical therapists. Tricare recently allowed for telehealth for physical therapists to be reimbursed in some instances.
Advocacy can change this, and PPS and APTA have an excellent lobbying campaign and team on this issue. But their job is an uphill one as much of the health policy focus has been on mortality and health system capacity related to COVID-19. On the flip side, economic recovery efforts tend not to focus on health care providers as businesses, but on the needs of small and other businesses as a whole.
Then what about private payers? Fortunately, results have been encouraging as private plans who initially seemed to disallow flexibility triggered by the COVID-19 pandemic have budged. Led by United Health Care, Aetna, Blue Cross/Blue Shield and CIGNA provide some allowances for telehealth practice, billing and payment. The Big Five (except Humana) have certainly gone further than traditional Medicare. Hopefully others will follow suit, but there are hitches in how codes will be billed and reimbursed.
Payers’ stance illustrates a deeper issue: the way we have reimbursed for services like physical therapy is outdated and inflexible, especially for historic times like these. We urge you to keep working with PPS to push all payers – federal, state, and private – on these issues.
Additional Resources for Your Practice
PPS Hub on COVID-19: ppsapta.org/physical-therapy-covid-19.cfm
APTA Telehealth Posting: www.apta.org/PTinMotion/News/2020/3/16/TelehealthCOVID19/
CMS Guidance to Medicare Advantage Plans: https://www.cms.gov/files/document/hpms-memo-covid-information-plans.pdf
Robert Hall, JD, MPAff, is a Senior Consultant for PPS working to advocate with private payers. Prior to his work with PPS, he was the Director of Government Relations for the American Academy of Family Physicians, the access to care lobbyist for the American Academy of Pediatrics, the Director of Government Relations for the National Coalition for Cancer Survivorship, Counsel to US Senator Mark Dayton, Attorney Advisor to the US Securities and Exchange Commission, and Chief Clerk to the Texas House of Representatives Insurance Committee.