In light of the threat posed by the novel coronavirus, we’re seeing an expansion of telehealth provision. But, the information is tough to track right now, particularly regarding what applies to OT.
The members of the OT Potential Club have been working on pulling together legislative and reimbursement updates, and helping therapists mobilize when key votes arise.
Our role in helping people stay as healthy as possible is so critical right now. And, it is definitely time to mobilize to make sure patients have access to our care.
Below are some telehealth legislative/reimbursement updates from here in the US, but we definitely need your help to keep us up to date.
This is an issue that many of us will be facing individually in our places of work, but my goal is to leverage our community so we can work together on this quickly evolving and incredibly critical issue.
United States Medicare update:
Occupational therapists have now been added as an approved telehealth provider for Medicare
On April 30th, The Centers for Medicare & Medicaid Services (CMS) announced the long awaited news that occupational therapists, physical therapists, and speech language pathologists can now perform telehealth services for Medicare beneficiaries. Here is the AOTA summary. AOTA is seeking clarification whether this approval includes COTAs.
We have been waiting for this announcement since March 30, when a CMS announcement spoke of new occupational therapy codes. BUT, for some reason, OTs had not yet been approved as providers. Many therapists were part of the advocacy to finally arrive to the place where we could be approved providers. Thank you for all of your work on this!
We will do our best to keep you appraised of updates as they come out! If we are missing anything, please let us know in the comments.
E-visits and relaxation of HIPAA
A March 17th update from CMS regarding the provision of telemedicine did give OTs the go-ahead to provide e-visits. An e-visit is not a way to deliver full-blown therapy. I’m copying the relevant sections about OT e-visits and the relaxation if HIPAA below:
Clinicians who may not independently bill for evaluation and management visits (for example – physical therapists, occupational therapists, speech language pathologists, clinical psychologists) can also provide these e-visits and bill the following codes:
- G2061: Qualified non-physician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the 7 days; 5–10 minutes
- G2062: Qualified non-physician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 11–20 minutes
- G2063: Qualified non-physician qualified healthcare professional assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 21 or more minutes.
HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (HIPAA): 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
Here is the AOTA Summary of CMS Expansion of E-visits.
Private/commercial insurance coverage update:
Here’s the AOTA update on private/commercial insurance.
Shout out to my home state of Nebraska for creating this amazing Google Doc of the information they have gathered from the insurers in our state. If you have a resource like this for your state, please let me know!
The reality is that OTs are still tackling some situations on a state-by-state, payor-by-payor basis for private insurance, Medicaid, and other state-funded services. If you are not a member of your state professional organization, it is my recommendation that you join today.
You can also refer to the AOTA chart on State Actions Affecting Occupational Therapy in Response to COVID-19.
There is still a lot in flux and a lot to flesh out. Please let me know in the comments if you have any state-specific updates. And, of course, please verify all information before acting upon it.
Below, you’ll find a list of each state, with a link to where you can find the most current information about telehealth rules and regulations. If you decide to contact your state to seek out more information, we recommend that you ask the following questions:
- Can OTs practice telehealth according to state legislation?
- Is this temporary legislation?
- Can COTAs practice telehealth?
- Can those licensed in other states see patients in our state? If so, is this permanent, or is it a temporary waiver?
- Do we have any reciprocal arrangements or agreements with other states regarding telehealth provision?
- State OT board link
- Telehealth/COVID-specific info (this is mostly information about license renewals, but might be updated more as things unfold)
- State OT board link
- Telehealth/COVID-specific info (this is a page regarding expansion of telemedicine coverage)
Additional Telehealth Resources
We will be seeing many more resources coming out to help us navigate this new era of OT. The AOTA has a telehealth resources page with all of their information. And, at OT Potential, we are gathering information from all of the best sources we can find in our Telehealth Occupational Therapy Guide.
Our world is in flux, and our profession is adapting accordingly.
At OT Potential, we believe that the best way to do this is through collaboration and sharing what is (and what isn’t) working in your practice.
Please share with us in the comments. Or, the very best way to leverage our community is by joining the OT Potential Club. The OT Potential Club is our online evidence-based practice forum.