Teaching Your Staff Telehealth Charge Capture
Understanding the rules regarding care and putting processes in place.
By Meredith Castin, PT, DPT*
The idea of implementing telehealth into physical therapy practice can be somewhat intimidating.
Between the state-specific laws and requirements, the concerns about licensure, and the learning curve involved with using technology to deliver remote care, simply getting started can feel overwhelming. Factor in the uncertainty with billing, and launching a telehealth program means you could send some of your best therapists running for the hills.
Don’t let the murkiness around billing keep you from incorporating telehealth into your practice, though. Charge capture for telehealth services is not as painstaking as it sounds. This article will help you teach your staff how to effectively bill for services without losing your mind in the process.
Get the lay of the land
A physical therapist delivering teletherapy is held to the same standards of care as a traditional therapist practicing in a brick and mortar clinic—and if you can’t offer the same caliber of assessment and treatment as you offer to in-office patients, telehealth isn’t appropriate for that patient. Keeping this in mind will help you create systems to determine which patients are appropriate for telehealth, and which ones aren’t.
While you’re at it, you’ll want to ensure that your staff understands when telehealth is—and isn’t—appropriate, as well. Consider creating a rubric or flowchart that can help your team decide whether or not to take on a teletherapy patient. After all, if a patient isn’t appropriate for teletherapy, the payers that do reimburse for remote care might decline you anyway.
Here are some factors to consider when creating your flowchart:
State rules and regulations
Ahh, the joys of state-specific rules and regulations! They’re always changing, and it’s hard enough to stay on top of them without considering telehealth-specific nuances. We deal with all sorts of rules regarding licensure, supervision, and direct access specifications, so it should come as no surprise that each state has its own telehealth rules and regulations, too.
Be sure that your staff understands the specific rules and regulations for who can deliver remote care. Here are some important considerations regarding the state in which you deliver care:
- Is an initial in-patient visit required?
- Can physical therapist assistants deliver telehealth therapy treatments, or just physical therapists?
- Are assistants required to submit special paperwork?
- How do your state’s direct access rules affect rules regarding telehealth delivery?
Ellen Bunn, PT, DPT, clinical program manager for Physera, notes that some states have parity laws. This means that insurance companies are required to reimburse teletherapy services at the same rate as in-person services, provided that the level of care is the same. States that do not have parity laws might deny claims for PT services that are completed via telehealth.
Rob Vining, PT, MSPT, is the founder of PTLive, and he echoes Bunn’s recommendation to explore parity laws. He advises looking up your specific laws at The American Telemedicine Association’s State Activity page.1
Who you can treat—and who your therapists can treat—using teletherapy
Telehealth delivery is complicated because of the nature of care delivery. Treating remotely opens up all sorts of confusion around licensure.
There is a physical therapy compact, in which multiple states offer license reciprocity, but belonging to the compact is not required to practice teletherapy. At the time of this article’s publication, a physical therapist must be licensed in the state in which he or she is currently working (delivering the remote care) and also in the state in which the patient being treated is physically located. This can become complicated when you live in Arizona and want to treat a patient in Texas. All is well as long as you are licensed in both Arizona and Texas. But confusion arises when your patient travels to, say, California. This state is not in the compact, and if the therapist is not independently licensed in that state, he or she cannot technically treat the patient via telehealth anymore.2
Understand insurance rules and regulations
One of the most important considerations for telehealth providers is accurate billing. It’s crucial that you and your staff understand the types of insurance you accept, whether they will reimburse for telehealth, and which types of services will be covered.
Medicare does not currently reimburse for telehealth physical therapy treatments. And, since therapists cannot charge cash to Medicare patients for covered services, this essentially means that you really cannot deliver care to Medicare patients via teletherapy.3
Each third-party insurance company has its own requirements for telehealth PT, and we all know how fun it is to stay on top of all the payers’ unique rules. Bear in mind that insurance requirements are separate from a state’s own legal requirements. Insurance companies will often dictate numerous aspects of teletherapy, including:
- Types of visits
This is not to say you cannot treat according to your own clinical reasoning, but your payers might not reimburse you for the care. This is why it’s so important to have an up-to-date reference manual for your therapists to reference when they deliver care. Expecting them to keep track of everything on the fly is asking for declined reimbursements.
Vining recommends creating a notebook where you collect the specifics for each insurance company. He suggests that you:
- Call the insurance company and ask if they have specific forms or anything specific when submitting charges for telehealth physical therapy. If you’re in a parity state, you might need to remind the insurance company of that fact if they are pushing back about telehealth.
- Write down each particular thing the insurance representative tells you that they need before they approve reimbursement.
- Call the company back two days later and ask for a new representative and repeat steps 1 and 2. If you get a consistent answer, you can feel confident adding this information to your notebook.
Once you have several representatives on record as recommending the same steps, Vining recommends moving on to the next insurance payer and repeating steps 1, 2, and 3.
It’s tough enough to be a savvy documenter with traditional patient care. It’s even more difficult with teletherapy. However, if you ensure that your documentation includes justification for remote care delivery, you should be in good shape.
For example, if you can prove that remote care creates less tactile dependence on a therapist, helps a patient receive needed care that wouldn’t be possible otherwise, or teaches specific motor-learning strategies that increase independence, you’ll be in much better shape than simply writing your notes without mentioning why the care was delivered via teletherapy.
Bunn also points out that you need to specify O2 as the location of service in your documentation. She also recommends limiting your coding to ones that are used most frequently when billing for telehealth.
Some commonly used billing and documentation codes include:
- Therapeutic Exercise (97110)
- Therapeutic Activities (97530)
- Self Care/Home Management (97535)
- Neuromuscular re-education (97112)
Don’t forget about remote patient monitoring
There is a CPT code (99091) that physical therapists are now able to use in certain states for “remote patient monitoring.” This contrasts with the old restriction that reimbursement was only provided for one-on-one (“synchronous”) treatments.
“Remote patient monitoring does not require a live visit with a patient via video,” explains Bunn. She notes that remote patient monitoring can include things like reviewing health data and consulting with the patient after the data is collected. For example, if a patient wears a biosensor that tracks movement, the data collected by the device may be analyzed by a clinician.
Using CPT code 99091, the time spent reviewing and communicating this data with the patient is a billable service if reviewed by a “qualified health professional.” Physical therapists are considered qualified practitioners under these regulations.4
Bunn notes that several rules apply. For example, you can only use the code once per patient in a 30-day period, and that coverage for this code varies per insurance plan.
Putting it all together to teach your staff
You might have all the answers to these considerations at your fingertips already. If so, that’s fantastic! But the hardest part can be teaching staff what you already have in your head.
As Vining mentioned, a reference notebook is always helpful. A flowchart or decision-tree can also help first-time telehealth providers feel more confident.
Designate an expert
It’s also strongly recommended to have a telehealth physical therapy expert on your staff. When questions arise, as they are bound to, you will want someone to provide consistent guidance to therapists. This also helps members of your staff build nonclinical skills on their résumés. Elect a telehealth policy leader on your staff, and build in some time each week for him or her to incorporate the latest state-specific changes, federal changes, and insurance changes that need to be reflected in your policies and procedures.
1ATA. (n.d.). State Activity – ATA. [online] Available at www.americantelemed.org/policy/state-activity. Accessed July 8, 2019.
2Ptcompact.org. (n.d.). Home. [online] Available at http://ptcompact.org. Accessed July 3, 2019.
3Castin M. (2018). Telehealth Physical Therapy – Everything You Need to Know | The Non-Clinical PT. [online] The Non-Clinical PT. Available at https://thenonclinicalpt.com/telehealth-physical-therapy. Accessed June 26, 2019.
4Cms.gov. (2018). Information on Medicare Telehealth. [online] Available at www.cms.gov/About-CMS/Agency-Information/OMH/Downloads/Information-on-Medicare-Telehealth-Report.pdf. Accessed July 8, 2019.
Meredith Castin, PT, DPT, is founder of The Non-Clinical PT, the #1 resource for physical therapy professionals seeking non-clinical health care careers. She can be reached at firstname.lastname@example.org.
*This author has a professional affiliation with this subject.