Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare
CMS posted an updated COVID-19 FAQ a couple of hours ago (the document shows yesterday’s date). As with each FAQ updated, you’ll see the date for each specific item that is accompanied by the word New – both in very small type. This is a 71-page document and it provides a specific unexpected gift for rehab therapists, therapy and billing in institutional settings. Head for pages 70 and 71 to see this breaking news regarding telehealth/use of telecommunications technology (3 questions):
FF. Outpatient Therapy Services
Question: Can outpatient therapy services that are furnished via telehealth and separately paid under Part B be reported on an institutional claim (e.g., UB-04) during the COVID-19 PHE?
Answer: Yes, outpatient therapy services that are furnished via telehealth, and are separately paid and not included as part of a bundled institutional payment, can be reported on institutional claims with the “-95” modifier applied to the service line. This includes:
- Hospital – 12X or 13X (for hospital outpatient therapy services);
- Skilled Nursing Facility (SNF) – 22X or 23X (SNFs may, in some circumstances, furnish Part B physical therapy (PT)/occupational therapy (OT)/speech-language pathology (SLP) services to their own long-term residents);
- Critical Access Hospital (CAH) – 85X (CAHs may separately provide and bill for PT, OT, and SLP services on 85X bill type);
- Comprehensive Outpatient Rehabilitation Facility (CORF) – 75X (CORFs provide ambulatory outpatient PT, OT, SLP services);
- Outpatient Rehabilitation Facility (ORF) – 74X (ORFs, also known as rehabilitation agencies, provide ambulatory outpatient PT & SLP as well as OT services); and
- Home Health Agency (HHA) – 34X (agencies may separately provide and bill for outpatient PT/OT/SLP services to persons in their homes only if such patients are not under a home health plan of care).
Question: Can therapy services furnished using telecommunications technology be paid separately in a Medicare Part A skilled nursing facility (SNF) stay?
Answer: Provision of therapy services using telecommunications technology (consistent with applicable state scope of practice laws) does not change rules regarding SNF consolidated billing or bundling. For example, Medicare payment for therapy services is bundled into the SNF Prospective Payment System (PPS) rate during a SNF covered Part A stay, regardless of whether or not they are furnished using telecommunications technology. Therapy services furnished to a SNF resident, whether in person or as telehealth services, during a non-covered SNF stay (Part A benefits exhausted, SNF level of care requirement not met, etc.) must be billed to Part B by the SNF itself using bill type 22X, regardless of whether or not they are furnished using telecommunications technology.
Question: Can outpatient therapy services be furnished and paid separately for patients receiving Medicare home health services?
Answer: No. For patients under a home health plan of care, payment for therapy services (unless provided by physicians/non-physician practitioners) is included or bundled into Medicare’s payment to the HHA, and those services must be billed by the HHA under the HHA consolidated billing rules. Patients should first be assessed for whether they are eligible to receive therapy services under the home health benefit prior to initiating outpatient therapy services. Receiving therapy services under the home health benefit may be in the best interest of the patient as there is no applicable coinsurance, copay, or deductible for such services (with the exception of negative pressure wound therapy using a disposable device), and the patient may also have a need for skilled nursing services, home health aide services, or medical social services under the home health benefit. However, if the patient is not eligible for home health care, including when it is not possible to provide in-person therapy services in the patient’s home (i.e., the patient is not under a home health plan of care), then outpatient therapy furnished via telehealth under Part B could be an appropriate alternative and separately billed, assuming all applicable requirements are otherwise met.
The National Association for the Support of Long Term Care (NASL; Briggs Healthcare is a proud member of this association) released this statement following the posting of the updated FAQ, specific to this telehealth announcement:
“Gaining this authorization has been a high advocacy priority for NASL, especially during the public health emergency as patient access to rehab therapy has decreased due to federal guidance on screening protocols. NASL is very pleased to announce this policy is now approved. This is an important win for both patients and therapists! Patients in settings impacted by COVID-19 have experienced decreasing access to rehab therapy due to necessary screening protocols that limit clinicians accessing facilities. These necessary screening protocols have reduced the number of therapists that can access patients in nursing facilities. NASL has relentlessly advocated for the ability of therapists to utilize telehealth technology as a means of extending the reach of the therapist to the patient without having to enter the facility. CMS had utilized new authority given to it in the CARES Act to allow for outpatient therapy to be provided via telehealth. Initially, CMS only allowed the use of telehealth in a few settings, but not all settings where outpatient therapy is billed, particularly the institutional settings. NASL, in partnership with other therapy organizations, has worked diligently to gain this ability in order for therapists to access patients safely and to protect the health and safety of residents, as well as other caregivers … we hope that this new ability for rehabilitation therapists to utilize and bill for telehealth in the institutional settings will be helpful in delivering the medically necessary care that this vulnerable Medicare population both needs and deserves.”
There are also other new items on this FAQ:
- Page 15 … Question #18 … Special waivers or exemptions that only apply to hospitals paid under TEFRA
- Page 15 … Question #19 … Transfer of patient to a temporary acute care location operated by the state, military or other public entity during the COVID-19 PHE
- Pages 16 thru 22 … Questions #1 thru 12 … Hospital IPPS under the CARES Act
- Pages 31 thru 34 … Questions #11 thru 23 … Expansion of Virtual Communication Services for FQHCs/RHCs
- Pages 42 thru 46 … Questions #23 thru 33 … Medicare Telehealth
- Page 57 … Question #3 … General Billing, COVID-19 Retesting
- Pages 69 and 70 … Question #1 … ICD-10-CM Coding of COVID-19
- Page 70 … Question #1 … Chronic Care Management Services
There is a great deal of information within the FAQ, complete with dates and hyperlinks. I encourage you to review these latest items as they pertain to you/your setting/practice; also check out the “older” FAQs to make sure you have good information on COVID-19 and CMS.