Transitioning to Telehealth Physical Therapy During the COVID-19 Crisis
By Robbie Leonard, PT, DPT*
Note: This information is current as of May 15, 2020. Information is changing daily if not hourly, so please remain up to date with changes by following reputable sources like the PPS website. This article does not contain state-specific information, so reference information pertinent to your state. This article is not intended to serve as legal advice, and it only reflects our interpretation of the information that exists.
The COVID-19 crisis has impacted the physical therapy industry in a number of ways, especially the ability to provide in-person therapy. PPS and the physical therapy private practice community have been increasingly exploring telehealth as an option to continue providing therapy for patients. Transitioning to telehealth requires determining a plan that works in your market and implementing that plan in light of regulatory and payment challenges.
Telehealth PT is an effective and reliable option for continued therapy when in-person treatment is no longer possible. A University of California-Irvine School of Medicine study1 recently showed that telehealth PT was equally as effective as in-clinic therapy for improving upper extremity motor control post-CVA. Similarly, a review2 of 75 systemic reviews and 71 Cochrane reviews revealed that the most effective interventions for lower back pain (LBP) are patient self-management, psychosocial interventions, and therapeutic exercise, all of which are supported by telehealth physical therapy. Additionally, there is a high level of agreement between in-clinic and remote diagnoses using a functional movement screen (FMS) via telehealth according to a 2016 study.3 These and other studies have shown the validity of telehealth physical therapy over the past several years, making us confident that it can provide an avenue for continued excellence in physical therapy during the COVID-19 crisis.
With your patient population and budget in mind, there are a few questions to consider when selecting a vendor for telehealth PT:
- Does it have proper security (encryption, signed BAA, HIPAA/HITECH compliance)?
- Is the platform easy to use for both patients and staff?
- What are the devices, systems, and browsers it is designed to run on?
- Is there a mobile app? What devices are supported?
- Is it cloud based or does it require software installation?
- Can the solution be integrated with your existing scheduling or EMR system?
Also consider how the platform operates at each level of processing. Learn how the platform may enable you to schedule patients, obtain consent, and identify the patient when they connect. You will also need set up processes for documenting the session, collecting co-pays/deductibles, and collecting registration information for new evaluations. There are several telehealth HIPAA-compliant platforms to choose from. We know therapists who currently use Doxy.me, MedBridge, and Zoom for Healthcare. Other HIPAA-compliant platforms include Anywhere Healthcare, BlueJay, eVisit, Health Recovery Solutions, PT Everywhere, In Hand Health, Phzio, PTLive, Relexion Health, and VSee.
HIPAA AND LEGAL CONSIDERATIONS
In addition to selecting a HIPAA-compliant platform for telehealth physical therapy, there are several other HIPAA, legal, and ethical considerations. The therapist and patient should have areas of privacy during their telehealth visit. Staff should use protected or encrypted devices, as well as protected connections, in order to maintain patient privacy. Additionally, consider the process for obtaining informed consent. You will also want to check with your liability insurance to make sure that your plan covers telehealth services.
Laws pertaining to telehealth vary by state, so check your state practice act for any telehealth restrictions. You will also want to check licensure requirements in both the clinician and patient location.
INSURANCE COVERAGE AND VERIFICATION
Commercial payers vary in their telehealth policies. Considering the circumstances, find out if commercial payers in your area are making exceptions during this crisis. Some states have made a mandate specific to the COVID-19 crisis, such as Massachusetts, so check if there is a mandate relevant to you.
There are several insurance verification questions to consider:
- Is physical/occupational therapy covered for telehealth for this payer?
- Does this payer specifically cover live video telehealth visits?
- Are there any restrictions on the number of telehealth visits a patient can have?
- Are there any restrictions on the location of the patient or provider?
- Are there any restrictions on the conditions a patient has to meet to qualify for telemedicine?
- Are the regular PT/OT CPT Codes covered for telehealth for therapy?
- Does the reimbursement rate match the in-person rate?
- Will the payer accept the 02 (telemedicine) place of service code for physical therapy?
- Do routine deductibles/co-pays/co-insurance policies apply?
STATE PARITY LAWS
State Parity Laws require private payers to reimburse providers the same amount for telemedicine as the comparable in-person service if telehealth therapy is covered (but a specific plan may or may not cover telehealth for therapy). The states with Parity Laws4 include: AZ, AR, CA, CO, CT, DE, DC, GA, HI, IN, KT, LA, ME, MD, MI, MN, MS, MO, MT, NV, NH, NM, NY, OK, OR, TN, TX, VT, VA, WA.
Medicare is covering telehealth services provided by private practices (physical therapists in private practice billing on a HCFA 1500 form) as of March 1, 2020 for the duration of the public health emergency. The CPT codes that are covered are as follows: 97161- 97164, 97110, 97112, 97116, 97150, 97530, 97535, 97542, 97750, 97755, 97760, and 97761. Reimbursement is at the normal in-clinic Medicare rates during this time. Patients can be established or new patients, and PTAs can also provide these services. Please click on this article for more detailed information. Medicare is also covering E-visits, phone assessment and management services and virtual check ins. Please visit www.apta.org/telehealth for more information on these types of services and what they entail. Please note that if your business is credentialed by Medicare as a Rehab Agency (services are billed on a UB04), telehealth is not covered by Medicare at the time this was written.
BILLING, CODING, AND DOCUMENTATION
Since there are no “telerehab” CPT codes, make sure the payer will allow for traditional CPT codes for therapy if telehealth is covered or ask for direction on the type of codes they allow physical therapists to use. Documentation should clearly indicate which services were performed via telehealth and why.
While working in telehealth physical therapy is similar to working in the clinic, there are many different guidelines and best practices for telehealth that staff should know. Staff should be trained in video etiquette, staff and patient introductions, scripted privacy discussions, and more.
Telehealth offers a unique opportunity to maintain patient interaction and care while generating potential revenue during COVID-19. Stay abreast of the current payment situation by visiting the PPS website for the most updated information. In addition, consider participating in the lobbying activities to promote parity in coverage. While telehealth does not replace the role of the physical therapist, during difficult times, it is helpful to know we have one additional tool in the modality repertoire.
1In-home therapy effective for stroke rehabilitation, study shows. Science Daily website. https://www.sciencedaily.com/releases/2018/05/180524120850.htm. Published May 24, 2018.
2Babatunde O, Jordan JL, Van der Windt DA, Hill JC, Foster NE, Protheroe J. Effective treatment options for musculoskeletal pain in primary care: A systematic overview of current evidence. PLOS One. http://doi.org/10.1371/journal.pone.0178621
3Mani B, Sharma S, Omar B. Validity and reliability of Internet-based physiotherapy assessment for musculoskeletal disorders: a systematic review. J Telemed Telecare. 2017;23(3). http://journals.sagepub.com/doi/abs/10.1177/1357633X16642369
4Center for Connected Health Policy. https://www.cchpca.org/
- APTA Telehealth Resource Page: www.apta.org/Telehealth
- State Telehealth and Reimbursement Policies: www.cchpca.org/sites/default/files/2019-10/50 State Telehealth-Laws-and-Reimbursement-Policies-Report-Fall-2019-FINAL.pdf
- Telemedicine Reimbursement Map: visuwell.io/telemedicine-reimbursement/map/
- The American Telemedicine Organization: thesource.americantelemed.org/home
- The Centers for Connected Health Policy: www.cchpca.org/
- Advance Beneficiary Notice of Noncoverage: www.cms.gov/Medicare/Medicare-General-Information/BNI/ABN
- CMS ABN FAQ: www.cms.gov/Medicare/Billing/TherapyServices/Downloads/2018-08-ABN-FAQ.pdf
- List of Medicare Administrative Contractors: www.cms.gov/Medicare/Medicare-Contracting/FFSProvCustSvcGen/MAC-Website-List
Robbie Leonard, PT, DPT, is a physical therapist and PPS member who has worked in private practice and as a consultant helping practice owners with revenue cycle management and administrative processes for the past 25 years. She can be reached at firstname.lastname@example.org.
*The author has a professional affiliation with this subject.