Telehealth – 5 Commonly Asked Questions for PT and Occupational Providers

Q: How often can you bill for the telehealth service.  (cumulative time during the 7 days) 

Answer:  PT Providers should only bill for telehealth visit to satisfy the total cumulative time spent with the patient during the 7day work week. 

Example:  Provider performs E-Visit on Monday-10min,  Tues-10 min,  Thurs-10min, the appropriate way to bill is to calculate the total time spent providing telehealth service and bill at the end of the week with G2063 and appropriate modifiers to the carriers.   

Q. When does the Notification of Enforcement Discretion regarding COVID-19 and remote telehealth communications expire?  

Answer: The Notification of Enforcement Discretion does not have an expiration date. OCR will issue a notice to the public when it is no longer exercising its enforcement discretion based upon the latest facts and circumstances. 

Q. Where can health care providers conduct telehealth?  

Answer: OCR expects health care providers will ordinarily conduct telehealth in private settings, such as a doctor in a clinic or office connecting to a patient who is at home or at another clinic. Providers should always use private locations and patients should not receive telehealth services in public or semi-public settings, absent patient consent or exigent circumstances. If telehealth cannot be provided in a private setting, covered health care providers should continue to implement reasonable HIPAA safeguards to limit incidental uses or disclosures of protected health information (PHI). Such reasonable precautions could include using lowered voices, not using speakerphone, or recommending that the patient move to a reasonable distance from others when discussing PHI. 

Q: Are the telehealth services only limited to services related to patients with COVID-19?  

Answer: No. The statutory provision broadens telehealth flexibility without regard to the diagnosis of the patient. This is a critical point given the importance of social distancing and other strategies recommended to reduce the risk of COVID-19 transmission since it will prevent vulnerable beneficiaries from unnecessarily entering a health care facility when their needs can be met remotely. For example, a beneficiary could use this to visit with their doctor before receiving another prescription refill. However, Medicare telehealth services, like all Medicare services, must be reasonable and necessary under section 1862(a) of the Act. 

Q: Are there beneficiary out of pocket costs for telehealth services?  

Answer: The use of telehealth does not change the out of pocket costs for beneficiaries with Original Medicare. Beneficiaries are generally liable for their deductible and coinsurance; however, the HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs. 

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