Many physical therapy centers began providing telehealth at the start of the COVID- 19 public health emergency (PHE). In 2020, the Centers for Medicare & Medicaid Services (CMS) CMS added 11 new services to the list of telehealth services covered by Medicare during the COVID-19. The CY 2023 Medicare Physician Fee Schedule (PFS) final rule issued by CMS has some significant changes for telehealth, which will impact billing for physical therapy services. As a physical therapy medical billing company, we stay updated on these developments to seamlessly handle telehealth billing for our clients.
Billing Virtual Physical Therapy in 2023 – Key Points
During the COVID-19 PHE, Medicare pays for real-time face-to-face telehealth furnished by physical therapy providers and physical therapy assistants under Medicare Part B. Physical therapists can bill for telehealth services for 151 days after the PHE ends. Many of the basic rules for billing these services still apply and are reviewed below:
- Telehealth services can be furnished in any geographic area and in any originating site setting (including the beneficiary’s home). Claims can continue to be billed with the place of service code that would be used if the telehealth service had been furnished in-person through the later of the end of CY 2023 or end of the year in which the PHE ends.
- Telehealth visits will continue to require the appropriate therapy modifier when delivered by a PT. Modifier 95 (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) should be appended to identify services furnished as telehealth services.
- E-Visits or Online Digital Evaluation and Management (E/M) Services: These are patient-initiated services that must take place on a secure HIPAA-compliant platform that allows for digital communication. The patient should be established.
- Online digital E/M services are billed once during a 7-day period-which begins on the initial review of the patient’s inquiry. The cumulative time for these services cover the time the physical therapist takes to:
- review the initial inquiry,
- assess the patient’s problem,
- interact with other healthcare professionals regarding the patient’s problem,
- develop management plans (including prescription generation or test ordering), and
- communicate with the patient through HIPAA-supported digital communication tools
- Several codes have been added to the “category 3” list of codes for which PTs can be paid when delivered via telehealth through 2023 (PTs’ ability to bill these codes in association with telehealth will cease when the public health emergency and add-on days end or until midnight Dec. 31, 2023, whichever comes first).
- Remote Therapeutic Monitoring or RTM allows providers to bill for the remote therapeutic management of their patients for musculoskeletal conditions using medical devices to collect non-physiological data. The 2022 fee schedule rule added five CPT codes for remote therapeutic monitoring. Three of the codes were for RTM services, while two – 98980 and 98981 – were for RTM treatment management services. All eligible providers including physicians, physical therapists and occupational therapists can bill CPT codes 98980 and 98981 for the treatment management services and receive the same reimbursement rates.
- RTM services may be furnished under general supervision. Beginning January 1, 2023, RTM services, if furnished by a therapy assistant, must be provided under the physical therapist’s supervision.
- CMS reiterated in the Final Rule that as audio-only services are generally not analogous to in-person services, they will not be separately covered on the Medicare Telehealth Services List after the 151-day extension period following the PHE.
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Telehealth-eligible CPT codes for Physical Therapy
There are no specific telehealth CPT codes for physical therapy. When billing a telehealth visit, indicate the covered service (e.g., gait training), choose the appropriate CPT code (e.g., 97116), provide the correct POS code and modifier as per the payer’s specifications, and complete the claim as is the normal practice. The CPT codes that can be used to bill tele-PT services are as follows:
- 97161, 97162, 97163, 97164 – Physical therapy evaluations
- 97161 Pt eval low complex 20 min Available Through December 31, 2023
- 97162 Pt eval mod complex 30 min Available Through December 31, 2023
- 97163 Pt eval high complex 45 min Available Through December 31, 2023
- 97164 Pt re-eval est plan care Available Through December 31, 2023
- 97110 – Therapy procedure using exercise
- 97112 – Neuromuscular reeducation
- 97116 – Therapeutic procedure, 1 or more areas, each 15 minutes, gait training
- 97530 – Therapeutic activities
- 97535 – Self-care/home management training
- 97542 – Wheelchair management
- 97750 – Functional capacity evaluation
- 97755 – Assistive technology assessment
- 97760 – Orthotic training
- 97761 – Orthotic, prosthetic training
After the start of the COVID-19 pandemic, Medicare began paying for real-time face-to-face telehealth furnished by physical therapy providers and physical therapy assistants under Medicare Part B. However, Medicaid and commercial payers may have different billing protocols from Medicare. For instance, Medicaid policies on the originating site and real-time vs asynchronous services differ among states. That’s why providers must carefully review individual payer policies to determine their billing preferences for telehealth and other virtual care services.
Companies providing medical billing and coding services keep abreast of industry changes to help qualified health professionals bill correctly for services rendered. Their coding and billing specialists will review resources provided by CMS, the APTA, and different payers to stay informed about the evolving situation, which is crucial to ensure accurate claim submission in 2023 and beyond.
Julie Clements, OSI’s Vice President of Operations, brings a diverse background in healthcare staffing and a robust six-year tenure as the Director of Sales and Marketing at a prestigious 4-star resort.