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An Enigma for Years, It’s Time for Telerehabilitation. Here’s How.

Published On 5.4.20

By William Dieter, PT, DPT, GCS, FSOAE

Director of PT Clinical Services

Physical therapists, occupational therapists, and speech-language pathologists have always pushed for innovation, and telerehabilitation has been at the top of the list! However, telerehabilitation has been an enigma – often discussed and held as a beacon of progress rather than implemented into patient care.

The translation of our hands-on, in-person models of care into a virtual environment has been limited, at least in part, by regulation. Much of that has recently changed during this unprecedented time.

PTs, OTs & SLPs: Here’s What You Need to Know to Provide Telehealth

The COVID-19 pandemic and governmental emergency declaration pressed fast-forward on telerehabilitation. Recent rule changes have allowed physical, occupational and speech therapists to provide telerehabilitation and e-visits to Medicare beneficiaries and many commercial insurances.

As government agencies have worked to remove policy barriers to telehealth, the first major development was the short term relaxation of some Health Insurance Portability and Accountability Act (HIPAA) requirements. The Office for Civil Rights (OCR) has stated, “Health care providers may use popular applications that allow for video chat…without risk that OCR might seek to impose a penalty.” While it is recommended that covered entities remain diligent in guarding protected health information (PHI), this temporary regulatory change allows providers that have not previously treated via telehealth to do so rather quickly.

Other requirements have remained unchanged. Including telehealth in your consent and notice of privacy practices, documenting the audiovisual platform, and using the -95 modifier, have all been consistent requirements. However, Medicare and a few other commercial insurances have specified that POS (place of service) 02 should not be used to identify the service as telehealth. The ongoing guidance from government and commercial payers makes this a topic any provider will have to stay up to date on.

The coronavirus crisis also created an opportunity for another type of virtual care: e-visits. E-visits, while performed virtually, are not true telerehabilitation. They allow a physical, occupational, or speech therapist to bill for time spent answering specific questions or concerns brought to them by their current patients who are not actively being seen. One of three Healthcare Common Procedure Coding System (HCPCS) codes (G2061, G2062 or G2063) is billed over a 7-day period depending on the total amount of time spent. Many commercial insurances are allowing e-visits and waiving co-pays, but providers should confirm with each payor. It’s important to double-check additional information about e-visits for Medicare beneficiaries.

3 Important Factors to Consider for Your Patients’ Care & Coverage

This all sounds like great news, right? Well, yes and no. While some requirements have been relaxed we, as therapists, have three factors to consider. First, no one is quite sure how long any of this will last. Many payers are only allowing therapists to perform telerehabilitation during the current public health emergency. The use of telerehabilitation after that point is unknown. Second, you must always defer to your state practice act to determine if you can legally provide telerehabilitation. Third, you have to consider what is clinically appropriate. Can the interventions you are providing still be effectively delivered through telehealth? Perhaps the patient needs a mix of telehealth and in-person visits. This will be a decision for each patient.

At the end of the day, many patients need access to therapy services, and telerehabilitation is a viable solution. We are in a position to take advantage of technology, apply the available evidence, and develop telerehabilitation approaches to benefit our patients in both the short and long-term.

Now you know how to get started.

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