Originally Published in APTA Hawaii’s Monthly e-Newsletter – April 2020
With the ever changing environment with the COVID-19 pandemic, we’ve heard and received many questions and comments about e-visits and telehealth by physical therapists in Hawaii.
First of all, our state Practice Act and Administrative Rules are “silent” about whether PTs and PTAs may provide care using telehealth. But we have clarified through the Board of Physical Therapy that PTs may indeed use telehealth and that PTs may perform an initial evaluation via telehealth too. The standards of care are not waived when using telehealth, however, so PTs and PTAs delivering care in this way still need to use their clinical judgement about whether they can meet standards of care for each patient episode.
While CMS still will not pay for telehealth care provided by PTs and PTAs, they recently waived certain restrictions on digital communication regarding e-visits and the use of its HCPCS codes G2061-G2063. An e-visit is described by CMS as non face-to-face patient-initiated digital communications that require a clinical decision that otherwise typically would have been provided in the office. Following the CMS announcement some Hawaii payers have made some payment policy changes regarding overall telehealth and e-visits.
But e-visits and telehealth are not the same thing. According to APTA, “An e-visit is considered a service furnished remotely using technology but is not considered a Medicare telehealth service. An e-visit does not constitute telehealth under the Medicare definition.” The good news is – e-visits do not count toward Medicare therapy thresholds.
Per the Medicare Fee Schedule for Hawaii, e-visit codes are described and reimbursed at the following rates:
1) G2061- $12.61 (for an established patient, for up to 7 days, cumulative time during the seven days 5-10 minutes)
2) G2062 – $22.22 (for an established patient, for up to 7 days, cumulative time during the seven days 11-20 minutes)
3) G2063 – $34.83 (for an established patient, for up to 7 days, cumulative time during the seven days 21 minutes and greater)
An e-visit was designed for short-term management of a patient on cumulative time spent over a 7-day period starting after the in-office visit and will end after 7 consecutive days. The patient also needs to initiate the e-visit and it is not meant to be for an on-going consultation. Also clarified by APTA an e-visit cannot be billed if a “face to face visit occurs within 7 days before or within 7 days after the e-visit.”
Locally, who will pay for these G-code e-visits? HMSA, UHC, Aetna, and CIGNA have come out with policy changes to allow for payment. We have asked HMSA what codes will they accept for e-visits with commercial and Quest Integration plans as well as what they would pay for the G-codes, but as of now they are not able to give us definitive answers. For large national payers like UHC, Aetna, and CIGNA – sometimes their local offices or third-party administrators don’t carry out what is reported nationally. So what is said and what is actually done may not be the same.
There are no local commercial plans that will cover the CPT codes 98970, 98971, 98972 (which are similar to the G-2061-63 codes) when the care is provided by a PT. Also keep in mind that PTs are not allowed to use 99421, 99422, and 99423, which are evaluation and management codes. PTs are also not allowed to use 99441-99443 (telephone services). Telephone assessments are 98966-98968 but Medicare has not provided guidance on the use of these codes by PTs at this time.
Things have been very fluid, so by the time you read this, payers may start to change payment policy for both e-visits and also to allow PTs to do true telehealth (meaning billing and getting paid for the usual 97000 code set). While we will try to keep you updated, the best thing for you to do is to double check with your payer. APTA recommends you ask the payers these questions:
- Will services provided by physical therapists (and PTAs working under the direction and supervision of the PT) be covered when provided via telehealth?
- If so, what codes should be billed and what modifiers are required?
- What device(s) or application(s) can be utilized?
- What, if any, consents are required?
- Are there any special documentation requirements?
APTA Hawaii has been in contact with our state’s largest payer HMSA and they are exploring telehealth options for PT, but HMSA has not come out with a revised payment policy at this time. So despite the HSMA commercials you see on TV that they are expanding telehealth services for all and that they are waiving co-payments, etc. – sadly this is not for PTs (or at least not yet). But stay tuned.
What else is HAPTA doing? We have sent a request to Gov. Ige asking him to mandate that local payers allow PT and PTA providers to deliver telehealth services and to pay for them at the same rate as in-person rates (similar to what other states have done in the last couple of weeks).
Key takeaways – stay tuned; the only constant is change right now.
Patti Taira-Tokuuke and Shawna Yee
APTA Hawaii Payer Relations Committee Co-Chairs
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