Are You Making The Most from the Telehealth Waivers?
Yesterday I sent the following letter out to our mailing list as an update to last year’s post about Telehealth:
As you may have heard, the telehealth waivers have been extended with the Public Health Emergency (PHE), and so I wanted to take a minute to clarify important points to help your team make decisions about resident care. Throughout the pandemic, it is clear that the most vulnerable in our country are the frail elderly, and unfortunately, many of those affected are in the beloved population that we serve. And the level of contact and intimacy that occurs when one is providing personal care or transfer assistance to a resident is such that it is nearly impossible to stop the spread of this virus once it has taken a foothold in a facility. The CDC has indicated that “social distancing” along with proper PPE in conjunction with the vaccine are the best ways to combat the spread of the virus. Yet social distance when providing hands-on care to a resident is impossible, as we are often up close and personal with our residents as we provide care. However for situations when up close and personal is not required, make sure you are not missing an important option related to the waiver: telehealth for therapy providers.
The telehealth waiver is attached to the PHE designation and will likely continue as long as the PHE is in place. It is a fluid situation and we will continue to keep you informed as things change in the coming months, but in the meantime, read on for some limitations and important information to keep in mind as you utilize this option...
As you may recall, on April 6, 2020, CMS issued an Interim Final Rule (IFR) that added PT, OT, and SLP as qualified providers for telehealth services. Unfortunately, due to language in the rule, that really only applied to private practice and hospital settings. Thus began the advocacy effort on the part of trade associations such as APTA, AOTA, ASHA, NARA, NASL, and more, attempting to have telehealth added to the institutional settings (Skilled Nursing Facilities, Rehab Agencies, and Home Health). CMS has since made telehealth available in all therapy settings, including SNF, AL, and IL to both Part A and Part B patients.
You might be thinking, “Why is this a big deal? Why would we need to do telehealth with a Part A patient?”
Let me propose a scenario we have heard:
A small, rural facility only has a PRN PT or OT, and that PT or OT was exposed to COVID-19 in another facility or from the community. The therapist feels fine, but due to the exposure must be quarantined for a period of time and/or at least until a negative test is received. During that time, the facility has a Part A admission that needs a PT or OT evaluation. In this scenario, the PT or OT could complete that evaluation via telehealth (or “remotely” as CMS calls it) to allow the PTA or OTA to get started treating this patient.
The good news with the renewal is that if you are trying to stop the spread or limit the ongoing exposure to your residents, telehealth for both Part A and Part B is available to Medicare SNF residents. That said, there are some limitations: when CMS posted the IFR mentioned above and linked below, it outlined the CPT codes that could be billed by PT, OT, and SLP using telehealth. That list includes all the regular therapy modalities, but conspicuously did not include 92526 (treatment of swallowing dysfunction) and 92610 (evaluation of oral and pharyngeal swallowing function). Several of the therapy organizations have begun efforts to lobby CMS to include those two codes to also be available for speech telehealth treatment, but at this time they are not covered.
To clarify the Medicare language for you: CMS is saying that therapy services to Part A patients can be furnished “remotely” but these “remote treatments” are being billed as in-person visits. For Part B patients, Medicare is calling these services via technology “telehealth” and it is being billed as such. More information on telehealth and remote treatments can be found on the ever-growing Covid-19 Frequently Asked Questions document that CMS is maintaining at https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf.
We are following all of these updates closely, so stay tuned for more information as it becomes available. And if you have any questions I can help with, don't hesitate to reach out.
All the best to you, your team, and your residents,
Mark McDavid, OTR, RAC-CT, CHC
Seagrove Rehab Partners
