CMS will reimburse for therapy telehealth provided in SNFs, other institutional settings

The Centers for Medicare & Medicaid Services (CMS) has clarified that therapy practitioners in institutional settings billing Medicare Part B can bill telehealth services on a UB-04 form, retroactive to March 1, during the public health emergency (PHE). In an FAQ update dated May 27, 2020, CMS shared their response to the following question, which AOTA, along with a coalition of therapy stakeholders, posed in a meeting with CMS officials on May 21, as well as during several other calls with CMS in recent weeks:

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, and SLP services)
• Outpatient Rehabilitation Facility (ORF)—74X (ORFs, also known as rehabilitation agencies, provide ambulatory outpatient PT & SLP as well as OT services)
• Home Health Agency (HHA)—34X (agencies may separately provide and bill for outpatient PT, OT, and SLP services to persons in their homes only if such patients are not under a home health plan of care).

In the FAQ, CMS also clarifies that telehealth may be performed under Part A in a SNF, but it is not separately reimbursable because therapy is paid under a prospective payment system. The facility would receive the same bundled reimbursement it would receive if those services were provided in person during the PHE. Stay tuned to AOTA social media and the website. Additional information will be communicated as it is received.