COVID-19 is creating a dip in outpatient therapy appointments … and revenues.  However, due to recent regulatory waivers announced by CMS, hospitals have a unique opportunity to provide therapy services within the patient’s home. The following two options should be considered:

Option 1: E-Visits

The CMS has recently clarified that e-visit services are reimbursable by Medicare when performed by physical therapists, occupational therapists, or speech language pathologists. This allows therapists to manage the care of an outpatient when the patient is unable to or does not need to come to the hospital.

For Medicare, the following codes will be payable for therapy e-visits.

Note: These are estimated reimbursement amounts. Provider’s reimbursement varies based on geographic practice cost indices and other variables.

There are parallel codes that commercial insurances may prefer:

• 98970  Qualified non-physician health care professional online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5–10 minutes
• 98971 11–20 minutes
• 98972  21 or more minutes

Medicare coverage and payment of these virtual services is described in CMS’ Medicare Telemedicine Heath Care Provider Fact Sheet, dated March 17, 2020.

Additionally, effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency.  For more information: https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/index.html

Options 2: Outpatient Therapy in the Home

This option is not new.  However, many hospitals are unaware of this service model that allows hospitals to send its therapists to the home of an individual who is registered as an outpatient of the hospital but who is unable, for medical reasons, to come to the hospital to receive medically necessary therapy services.  Under qualifying considerations, the hospital may bill for these home therapy services directly to Medicare for reimbursement, in a manner consistent with therapy services provided within a hospital outpatient department.

For Medicare coverage and payment of outpatient home therapy services, please refer to CMS’ Benefit Policy Manual under Special Rules for Hospitals.

During this time of uncertainty, we hope your hospital considers these valuable options for providing hospital outpatient therapy services. For more information, contact John Britt, Senior Manager.

Please continue to monitor our Coronavirus Resources and Information Page and COVID-19 Relief & Operations FAQs for updates.