April 7, 2020
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Questions and Answers

The following are questions submitted in connection with the April 2 webinar titled “Getting Paid for PT/OT Telehealth and E-Visits” with answers.

I am at a hospital-based outpatient therapy clinic at a critical access hospital. Is there any difference from the rest of your presentation?

The information we shared should apply to telehealth and e-visits provided by therapists who work in a hospital-based outpatient therapy department including a critical access hospital.

Anthem BC of CA has sent out update letters almost daily.  They have stated all providers are allowed telehealth with the exception of PTs/OTs/SLPs as it has to be a face-to-face interaction. It’s confusing.

Anthem guidance has been confusing, but they have recently announced they will cover outpatient therapy via telehealth at the same rates as in-clinic treatment. Please see the link below:

Do you know if similar “rules” apply for SLP in terms of billing?  For clarity, OT-PT can see BCBS patients in Texas now and we do not have to charge a co-pay.

In Texas, similar rules should apply for SLP. BCBS of Texas is covering telehealth delivered by any in-network provider and is waiving co-pays. Please see the link below:

Once telehealth visits are authorized for Medicare, can we waive co-pays also?  How about UHC or Humana?

Medicare is giving providers the option of waiving coinsurance collections. UHC and Humana are waiving co-pays for telehealth visits and are presumably reimbursing providers for the waived co-pay (but we have not seen a written commitment to do so).

Which HIPAA-compliant telehealth communication tools are the least expensive in your opinion?  We all are hurting right now.

QliqSOFT is HIPAA compliant and only charges $15 per month per provider; however, it only works on smart phones, not iPads or computers.

You can use a non-public facing communication application that is not HIPAA-compliant for free. For example, FaceTime, Zoom, Facebook Messenger video chat, Google Hangouts video or Skype.

Will Medicare will be waiving co-pays?

Medicare is giving providers the option of not collecting coinsurance. (Ordinarily, providers are required by law to collect coinsurance from Medicare patients.)

What about PTAs and OTAs providing telehealth in CA?

We have not seen any written guidance from any payer regarding whether PTAs and COTAs can provide telehealth services. However, we feel it is safe to assume that PTAs and COTAs can provide telehealth services to patients who they could have treated in the clinic without a therapist on site. For example, because a PTA can treat an Anthem patient in clinic without a PT on site, the PTA should be able to do a telehealth visit with an Anthem patient.

Can a second, 7-day e-visit billing period be submitted?


Have Cigna, UHC, or Aetna allowed PTs and OTs as eligible telehealth providers?

          Yes.  Please see webinar slides.

Does a telephone visit also need to be initiated by the patient?

When allowed, e- visits and telephone visits should be initiated by the patient per the CPT code description. However, you can implement the following process: your clinic can tell patients that e-visits and/or telephone visits are available and the patient can contact the clinic to schedule an e-visit and/or telephone visit.  At the scheduled time, the provider can contact the patient to actually initiate the visit.

Do you think timely filing will be lifted by insurance companies?

We have not seen any specific announcement on this, but it would not surprise us given all of the disruption.

Can you please send a sample HCFA 1500 billing form for telehealth?

The 1500 form is going to vary depending on the payer because each payer is allowing different codes and specifying different modifiers. The information for Medicare and the major commercial payers is in the slides we sent out.  

Where do we find information about distant site requirements?  Does it need to be in a facility or can it be in therapist’s home?

Virtually every payer who is allowing PT/OT via telehealth is allowing the provider to be located in the provider’s clinic or at the provider’s home. Be careful with the place of service code because while the typical telehealth place of service code is 2, some payers are instructing providers to use place of service code 2 and others are requiring place of service code 11 (in clinic) regardless of where the therapist is located.

You mentioned waiving deductibles, co-pays and coinsurance. Is it okay to waive if the patient is still coming into the clinic?

No, the payers that are waiving co-pays are only waiving for telehealth, e-visits and telephone visits.

Does HHS override TRICARE with the HIPAA waiver to allow non-public facing communications?

Technically no, but we frankly expect that for care provided during the COVID crisis, TRICARE will not deny claims for telehealth provided via non-HIPAA compliant applications allowed by HHS.

Is the Medicare e-visit evaluation code different, or do we use the same 3 G codes with the correct minutes?

For e-visits, you should use the same three codes: G2061, G2062 or G2063.

Are there any waivers that allow hospital-based outpatient rehab departments to bill telehealth as an institution using the rehab providers’ NPI?

UHC, Aetna, CIGNA and many of the BCBS carriers are allowing in-network providers to treat via telehealth on the same basis as in clinic, so those payers should be allowing the hospital to bill for telehealth.  Medicare’s allowance for e-visits should also apply to hospital outpatient departments.

If telehealth is being provided from a home office by a PT as an independent contractor, what is the POS code?

Each payer is specifying which POS code to use.  Please refer to the webinar slides for the information we have for each payer.     

Is Zoom HIPAA compliant?

Zoom does have a HIPAA-compliant version; however, you should be able to use the free version of Zoom during the COVID crisis regardless of whether it is HIPAA-compliant per the HHS waiver.

Many of these insurers are asking for the “02” POS.  What do we do if we bill under hospital-based services on UB forms?

Each payer has its own modifier and POS specifications. 

In Arizona during the COVID orders, does Aetna cover initial assessment using telehealth, or just ongoing treatment?

Aetna is covering initial evaluations and treatment visits via telehealth in all states.

Are commercial payers likely to follow same Medicare rules?

The major commercial payers have adopted their own rules which are currently more flexible than Medicare rules.  Please see the webinar slides.

Does POS 11 need to be used for commercial payers also?

Each payer is specifying its required POS code for telehealth.  Payers that are paying for telehealth at the same rates as in-clinic visits are typically specifying POS 11, but check for each payer.

Why would POS be 11 if not in-office?  CMS FAQ states to use 02 as POS.

Each payer is specifying the modifiers and POS codes that it is requiring and there is considerable variation. Please see the webinar slides.

If a therapist is part of a POP but also has their own NPI that is typically used for billing, can we switch over and bill incident to the MD in the building for Medicare patients without issue?


School-based services are a subsection within Medicaid, right?

Typically, yes.

What date would you bill if you do several e-visits in a 7-day period?

For the DOS, we suggest using the date of the first e-visit during the seven-day period.

Where can I find more information on the “incident to” situation?

You can find Medicare’s rules regarding incident to billing in the Medicare Benefit Policy Manual, Chapter 5, Section 230.5.

For the Medicare e-visits, can that also be a telephone assessment?

Medicare allows e-visits or telephone visits. They are coded differently per the guidance in the webinar slides.

If a PT does an e-visit for a patient three times in a week, what date of service should we use to bill the visit?  I know we add the minutes to come up with the code, but wasn’t sure if we bill the code on the first call or the last call.

We have not seen any guidance on this, but frankly it should not much matter.  We suggest using the date of the first e-visit as the DOS.

Apparently, another employee saw the webinar and we came out with different views on how to bill for services.  Prior to telehealth, we billed all our physical therapy services incident-to for all our payers.  Can we now bill 97110, 97112, 97116, 97535, 97750 and 97760 for telehealth incident-to for all payers with place of service 2?

We only suggest using the incident to rules for Medicare patients receiving telehealth. For other patients, follow each payer’s rules. If, for example, your therapists are credentialed with UHC and claims for in-clinic UHC patients were being submitted under the therapist, do the same for telehealth visits.

I listened to your webinar and am looking to get some clarification on Illinois telehealth billing.  From what I have gathered, we are still able to bill as we normally would with normal codes, and just utilize the 95 for private payers and CR modifier for Medicare patients.  Can you expand/confirm this further for me?

Each payer is specifying what codes are allowed and what modifiers and place-of-service codes are required.

Most of the guidance on billing references claim form 1500 as a POS indicator.  The institutional sites that bill on UB04 are being left out of the discussion.  What direction is being given for our hospital-based OP sites to be able to bill for telehealth as it is approved with more payers?

CMS guidance on e-visits requires that institutions use the POS where the provider is located, DR condition code and CR modifier.

I’m wondering how the patient evaluation, goals and plan of care will be shared with me as the PTA, so that I can effectively treat the patient while still observing HIPAA guidelines in the Telehealth setting?

PTAs will need remote access to documentation if they are providing telehealth services from their homes. This access will need to be HIPAA compliant. This obviously depends on your documentation system.

How will the supervisory role of the PT/PTA relationship be addressed in the telehealth setting?

You should be able to apply the same supervisory rules as in the clinic. For example, if a PTA can treat a patient without a therapist on site in the clinic, the same rule should apply if the PTA is treating via telehealth.

You stated if you are a physician-owned clinic, the therapist could bill Medicare incident-to the physician or PA if the PA or physician was within supervision on the therapist.  We currently bill incident-to our therapists.  Are we now able to bill telehealth services incident-to the physician/PA?  I am not sure if I understood that correctly.  PTAs too.

As the Medicare rules currently stand, therapists should be able to bill telehealth services incident-to a physician or PA.  Medicare will not pay for PTA services billed incident to a physician or PA either in the clinic or via telehealth.

I am an OT working in the school system. What is Medicaid’s position regarding this?

Each state’s Medicaid system is different. You need to review your state’s Medicaid rules. Your school system should also be providing guidance.

We are setting up our system to auto populate POS 2 but are confused on what should be in box 32 on the 1500 form. Should it be our office info?

           Yes, but refer to specific payer rules for POS code.

What platform do you use for delivering PT Telehealth?

Providers are using many different platforms. For HIPAA-compliant platforms, we have heard good reviews of and C3HealthcareRX.

Concerning slide 12, I know we are still awaiting CMS adding PT/OT to the eligible providers, but I don’t understand the “POS 11 for in-clinic” statement.  If doing telehealth, why would we put 11 for in-clinic?  Wouldn’t it be 02 for the POS (not on site)?

A number of payers are specifying that PT/OT providers should use POS 11 for telehealth so that the providers are paid at in-clinic rates for telehealth during the COVID emergency.

For e-visits, I’ve read that a patient portal is needed.  Can a phone call and an online education tool, such as Medbridge, be used concurrently during this e-visit?  I was curious about the patient portal aspect.  Basically, I wanted to know if I can still bill my time with the patient if it’s over the phone and with the use of a secure, individual access account for exercises. 

The patient portal reference in e-visits is confusing. You can provide e-visits during the COVID emergency using any non-public facing audiovisual connection, such as FaceTime, Facebook messenger, Zoom, Google hangouts, etc. You do not need to use the typical patient portal.

You should note telephone visits are different than e-visits and are coded differently. Please see the webinar slides.

Do you have any knowledge of, or references for, monitoring of COTAs by OTs in treatment of home health patients?

Please see information above regarding PTA supervision and telehealth visits.

In your presentation you mentioned TRICARE only pays for telehealth for existing patients.  If I am in a state where there was a Governor’s executive order that all telehealth visits will be paid as in-person visits, do you think that would override the TRICARE rules and they would have to reimburse for new patients?  (Just using TRICARE as an example.)

Those state orders only apply to insurance plans regulated by the state. TRICARE is not regulated by any state, so TRICARE’s coverage of telehealth is not impacted by any state order. The state orders regarding telehealth basically only apply to commercial plans. Please also note that the state orders do not apply to Medicare Advantage plans.

With Medicare reimbursing for telehealth now, and being expected to add PTs as approved telehealth providers in the near future, I am curious; does the legislation and CMS statements specifically use wording that it is COVID-19 pertinent?  Do you expect Medicare to continue paying for telehealth after COVID-19?

The Medicare telehealth rules only apply during the COVID emergency. It is hard to say whether Medicare will extend PT/OT telehealth benefits after the emergency, because CMS has been reluctant to include PT/OT telehealth benefits.

Nevertheless, we do expect this situation to help the long-term efforts to allow and pay for PT/OT via telehealth.

How will we know that insurances have stopped paying for telehealth?

The payer websites include the dates for telehealth coverage which we expect will be extended.

Curious as to your personal opinion.  Do you think insurances will be more generous with their telehealth benefits in the future?  

We expect that the expansion of telehealth coverage will help to open up telehealth benefits in the future, but of course it is hard to say how and when at this point.

For somebody who is interested in providing telehealth in the future, what methods would you recommend in figuring out what payers would cover it?  Contact payers individually?  Any specific departments?  Any internet resources you would recommend for finding out about getting reimbursed for telehealth for non-emergency times?

Virtually every payer that is covering telehealth has announced this coverage and the details on the payer’s website.

I am a school occupational therapist and work at a private special education school that accepts kids from all across the State of New Jersey.  At our school, OTs, PTs and SLPs submit “SEMI” Medicaid billing monthly to our kids’ school districts.  Any word on if we will be doing Medicaid billing for any form of teletherapy that we provide?  Currently New Jersey has banned teletherapy for providing special education services but we believe it is only a matter of time until they lift the ban given the circumstances. 

This will be up to New Jersey. Medicaid (and other payers) are under a good deal of pressure to cover telehealth services during the COVID emergency.

I’m told SLPs have been able to do tele-med and are further along with reimbursement.  What do you know about that discipline?

The PT/OT rules will generally apply to SLP.

Who would be best to contact for Medicare home health and Medicaid HCS visits with regard to both being on the CMS alert waivers stating that telehealth would be reimbursed the same as a regular visit?

We suggest the home health agency section of the website and also the home health agency professional association.

Do you have any information about the POS, modifier, HIPPA waiver or platforms to use for the kids?  I see mostly Medicaid and MMA and few commercial insurance kids. 

This will be determined on a payer-by-payer basis. For children covered under the typical commercial plan, the commercial plan rules regarding modifiers and POS codes should apply.

Can a home health agency provide PT/OT services via telehealth?

CMS issued rules in connection with home health agencies providing telehealth services in what has become known as the Interim Final Rule (“IFR”). The home health agency provisions are on pages 60-72 which can be accessed by using the following link:

There is very little specific guidance as to under what conditions a home health agency can provide PT/OT via telehealth. However, the IFR does state that “[i]n summary, we are amending the plan of care requirements at section 409.43(a) on an interim basis, for the purposes of Medicare payment, to state that the plan of care must include any provision of remote patient monitoring or other services furnished via a telecommunications system, and that these services cannot substitute for a home visit ordered as part of the plan of care and cannot be considered a home visit for the purposes of patient eligibility or payment.” (emphasis added)