New guidance issued by the Centers for Medicare and Medicaid (CMS) that came into effect with a retroactive effective date of March 1, 2020 through the end of the emergency, expanded the types of health care professionals eligible to furnish and bill for Medicare telehealth services. Physical therapists (PTs) and physical therapy assistants (PTAs) are among the private practitioners who can bill for services provided through real-time face-to-face technology. There are specific codes to bill PT services furnished via telehealth during the COVID-19 pandemic. A physical therapy medical coding company can help providers ensure accurate claim submission using the allowable CPT codes.

The basics of CMS guidance for PTs during the public health emergency (PHE) are as follows:

• PTs in private practice are eligible to bill Medicare for certain services provided via telehealth.
• Services that started as of March 1, 2020, and are provided for the duration of the PHE are eligible.
• Services may be provided to both new and established patients.
• The same services can be provided as would be provided during an in-person visit and are paid at the same rate.
• Services can be provided to patients in any geographic area and in any health care facility or in their home.
• There are specific CPT codes under the Medicare Physician Fee Schedule that PTs can use to bill services provided via telehealth

CPT Codes for Physical Therapy Services delivered via Telehealth during the Pandemic

The allowable CPT codes for PT services via telehealth are: 97161- 97164, 97110, 97112, 97116, 97150, 97530, 97535, 97542, 97750, 97755, 97760, and 97761 (all codes are Temporary Additions for the PHE for the COVID-19 Pandemic):

• 97161 – PT Eval low complex 20 min
• 97162 – PT Eval mod complex 30 min
• 97163 – PT Eval high complex 45 min
• 97164 – PT re-eval est plan care
• 97110 – Therapeutic exercises
• 97112 – Neuromusulcar reeducation
• 97116 – Gait training therapy
• 97150 – Group therapeutic procedures
• 97530 – Therapeutic activities
• 97535 – Self care management training
• 97542 – Wheelchair management training
• 97750 – Physical Performance Test
• 97755 – Assistive Technology Assess
• 97760 – Orthotic mgmt&traing 1st en
• 97761 – Prosthetic traing 1st enc

Medicare requires PTs to use the HCPCS G-codes to indicate when they provided an online digital E/M service

G2061: Qualified non-physician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the 7 days; 5-10 minutes

G2062: non-physician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 11-20 minutes

G2063: Qualified non-physician qualified healthcare professional assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 21 or more minutes

Modifiers

All claims for PT services delivered via telehealth services on or after March 1, 2020, and for the duration of the PHE, should be billed using the appropriate Place of Service (POS) code and modifiers:

• POS code equal to what it would have been if the PT had furnished the service in person
• Modifier 95, confirming that the services were provided via telehealth
• The GP modifier (that indicates that a physical therapist’s services were provided)

Technology Requirements and Security Considerations

PT services on the Medicare telehealth services list should be provided using, at a minimum, audio and video equipment that allows two-way, real-time interactive communication between the therapist and the patient. Medicare also pays separately for audio-only telephone assessment and management services described by CPT codes 98966-98968.

During the PHE, the HHS office for Civil Rights has relaxed enforcement and is waiving penalties for HIPAA violations against clinicians who in good faith use video chat applications such as Apple FaceTime and Skype. Providers should however, take care to adhere to any state laws governing privacy and security of patient data. The American Physical Therapy Association (APTA) recommends that providers consider providing video-based telehealth services through technology vendors that offer HIPAA business associate agreements with their video communication products.

Documentation Requirements

PTs need to provide comprehensive documentation of telehealth visits as for in-person visits. Medicare guidelines for defensible documentation should be followed. In addition to documenting informed consent, the type of technology used for the evaluation or treatment should be specified. Furthermore, as federal/state and third-party payer regulations govern provision of telehealth services and e-visits, and how they are reimbursed, providers should clearly understand their state practice act, all applicable administrative telehealth rules, and payer’s telehealth policies and documentation requirements.