The July issue of PT Connections is now available online to download.
There is so much going on in Wisconsin that gives us pause. Our personal and professional lives have been turned upside down by the Covid-19 pandemic. There is no time like the present to bring attention to those things that are positive in our worlds. Among my many blessings are being healthy, happy and…being a PT! At 70, I can truly say I have never once looked back or regretted my choice to become a PT. Along with being a PT, I am grateful that I stumbled into becoming a member of our professional association. The APTA/WPTA have provided me with lifelong friends, personal and professional growth, and motivation to be the best PT I was capable of being. Let us take a break from our worries and celebrate our profession and APTA as we move into 100 years of being.
The APTA has formed a committee to oversee our proud heritage. Wisconsin’s very own Reenie Kavalar serves on that committee. Additionally, volunteers from each state were invited to serve as ambassadors to maximize awareness and help plan local events.
Here are a list of the activities and events being planned by APTA during 2021.
As Wisconsin’s ambassador, I am inviting all of you to think about your life as a PT or PTA. Do you have pictures that might help with the chronology of physical therapy’s growth in Wisconsin? Do you have stories to share about practice through the years? Are there any artifacts like equipment, PT pins, badges, uniforms we could put on display at state meetings?
Please feel free to reach out to me with any ideas you may have for making this year meaningful. I also want to thank all of you who volunteered to be on Wisconsin’s centennial committee:
Gwyneth Straker (APTA ambassador)
Here is a link to the APTA website on Celebrating our Centennial: https://centennial.apta.org/
Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19
Great news for therapists and their Medicare patients!
Page 1 of the fact sheet (https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf) says:
Pursuant to authority granted under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) that broadens the waiver authority under section 1135 of the Social Security Act, the Secretary has authorized additional telehealth waivers. CMS is waiving the requirements of section 1834(m)(4)(E) of the Act and 42 CFR § 410.78 (b)(2) which specify the types of practitioners that may bill for their services when furnished as Medicare telehealth services from the distant site. The waiver of these requirements expands the types of health care professionals that can furnish distant site telehealth services to include all those that are eligible to bill Medicare for their professional services. This allows health care professionals who were previously ineligible to furnish and bill for Medicare telehealth services, including physical therapists, occupational therapists, speech language pathologists, and others, to receive payment for Medicare telehealth services.
On page 32 it says an effective date of March 1, 2020 and on page 31 it says that “Waivers under Section 1135 of the Social Security Act typically end no late rthan the termination of the emergency period, or 60 days from the date the waiver or modification is first published. The Secretary can extend the waiver by notice for additional periods of up to 60 days, up to the end of the emergency period.”
This means that PTs can do true telehealth billing a limited set of CPT codes: 97161- 97164, 97110, 97112, 97116, 97535, 97750, 97755, 97760, and 97761.
CMS Eased Several Coding Edit Changes
In private practice and institutional settings, PTs are now able to pair the following code combinations without the use of 59 or X modifiers:
97530 with 97116
97161 with 97140
97162 with 97140
97163 with 97140
97110 with 97164
97112 with 97164
97113 with 97164
97116 with 97164
97140 with 97164
97150 with 97110
97150 with 97112
97150 with 97116
97150 with 97164
There are additional edit changes as well, and APTA’s National Correct Coding Initiative webpage includes a table of the common edits that remain. Check back regularly as some of these edit changes may be temporary and could be reversed after the COVID-9 public health emergency ends.
TRICARE Manual Updated to Recognize PTAs as Authorized Providers
TRICARE, the health insurance system used throughout the military, announced that it has officially revised its policy manual to recognize PTAs (and occupational therapy assistants) as authorized providers, outlining the rules and requirements governing assistant qualifications, scope of practice, supervision, and reimbursement.
Now it's up to TRICARE contractors to do the same within approximately 30 days.
As reported earlier, beginning with date of service on April 16, PTAs are recognized as authorized providers under TRICARE and thus eligible for reimbursement for covered services rendered to TRICARE beneficiaries.
Take note: The CQ modifier must be appended to the claim when more than 10% of an outpatient physical therapy service is furnished by the PTA. Check out APTA’s Quick Guide to Using the PTA Modifier.
The presence of the modifier shouldn't impact claims processing. However, if claims are denied, they may need to be resubmitted if the claims are sent to contractors before they fully implement the change.
Today, the Department of Health and Human Services (HHS) is beginning the delivery of the initial $30 billion in relief funding to providers in support of the national response to COVID-19 as part of the distribution of the $100 billion provider relief fund provided for in the Coronavirus Aid, Relief, and Economic Security (CARES) Act recently passed by Congress and signed by President Trump.
The $100 billion of funding will be used to support healthcare-related expenses or lost revenue attributable to coronavirus and to ensure uninsured Americans can get the testing and treatment they need without receiving a surprise bill from a provider. The initial $30 billion in immediate relief funds will begin being delivered to providers today.
Recognizing the importance of delivering the provider relief funds in a fast, fair, and transparent manner, this initial broad-based distribution of the relief funds will go to hospitals and providers across the United States that are enrolled in Medicare. Facilities and providers are allotted a portion of the $30 billion based on their share of 2019 Medicare fee-for-service (FFS) reimbursements. These are payments, not loans, to healthcare providers, and will not need to be repaid.
HHS and the Administration are working rapidly on additional targeted distributions to providers that will focus on providers in areas particularly impacted by the COVID-19 outbreak, rural providers, and providers of services with lower shares of Medicare FFS reimbursement or who predominantly serve the Medicaid population. This supplemental funding will also be used to reimburse providers for COVID-19 care for uninsured Americans.
HHS is partnering with UnitedHealth Group (UHG) to deliver the initial $30 billion distribution to providers as quickly as possible. Providers will be paid via Automated Clearing House account information on file with UHG, UnitedHealthcare, or Optum Bank, or used for reimbursements from the Centers for Medicare & Medicaid Services (CMS). Providers who normally receive a paper check for reimbursement from CMS will receive a paper check in the mail for this payment as well, within the next few weeks.
Within 30 days of receiving the payment, providers must sign an attestation confirming receipt of the funds and agreeing to the terms and conditions of payment. The portal for signing the attestation will be open the week of April 13, 2020 and will be linked from hhs.gov/providerrelief.
UnitedHealth Group will donate all fees for the administration of the CARES Act provider relief fund.
Visit hhs.gov/providerrelief for additional information.
How are payment distributions determined?
Providers will be distributed a portion of the initial $30 billion based on their share of total Medicare FFS reimbursements in 2019. Total FFS payments were approximately $484 billion in 2019.
A provider can estimate their payment by dividing their 2019 Medicare FFS (not including Medicare Advantage) payments they received by $484,000,000,000, and multiply that ratio by $30,000,000,000. Providers can obtain their 2019 Medicare FFS billings from their organization's revenue management system.
As an example: A community hospital billed Medicare FFS $121 million in 2019. To determine how much they would receive, use this equation:
$121,000,000/$484,000,000,000 x $30,000,000,000 = $7,500,000
Are you interested in playing a critical role in helping Wisconsin’s health care system respond to the COVID-19 pandemic? If so, we need you!
In an effort to plan for the surge of patients that is expected to hit our heath care systems in the coming weeks, we are creating a wide network of volunteers to increase capacity at hospitals and clinics across Wisconsin. Both active and retired health care professionals can volunteer for these critical roles.
We are looking for the following types of licensed professionals:
We are also looking for volunteers for non-clinical support positions. If you are interesting in helping but are not a licensed health care professional, you can sign up to volunteer as well.
Volunteers will be assigned to locations across Wisconsin in support of ongoing efforts related to the COVID-19 national emergency. If you are willing to travel, let us know when you sign up. In order to volunteer to support the COVID-19 effort, you must complete a background check.
While we have shared this message with many partners and organizations, please feel free to share with other people or organizations you think would support this effort and help us get the call out for volunteers.
MADISON — Gov. Tony Evers today issued Emergency Order #22 to position the Wisconsin Department of Safety and Professional Services (DSPS) to continue providing its critical services by giving it flexibility to adapt to the new environments and circumstances due to the COVID-19 public health emergency. It covers a range of service areas and constituents, including fire departments, construction services, physical therapists and certified public accountants—all of which have faced new challenges as a result of this public health emergency.
Administrative Rule Suspensions and Orders
Admin. Rule: Wis. Admin. Code § PT 5.01(2)(b)
Description of Rule: Supervision of physical therapist assistants.
Status: Suspended in part as follows: “Have
direct face-to-face contact with the physical therapist assistant at least every 14 calendar days , unless the board approves another type of contact.”
Admin. Rule: Wis. Admin. Code § PT 5.01(2)(h)
Description of Rule: Supervision of physical therapist assistants.
Status: Suspended in part as follows: “Provide
on-site assessment and reevaluation of each patient’s treatment at a minimum of one time per calendar month or every tenth treatment day, whichever is sooner, and adjust the treatment plan as appropriate.”
These are personally and professionally difficult times. All of us are feeling challenged and uncertain about what tomorrow may bring. Many of you are experiencing changes within your practice setting. Some of these changes are making you uncomfortable. Your gut tells you that “this doesn’t feel right” but you do not know what to do with that discomfort. By no means am I suggesting that any change that causes you discomfort is ultimately a bad change. Nor am I saying that changes that do not make you feel uncomfortable are automatically good changes. I am saying all of us need a chance to think through change with our colleagues to bring clarity to the situation along with certainty of our actions. Over the past month, I have received numerous calls from those of you in the trenches with the need to dialog and discernment regarding the challenges you are facing. I have created a hybrid case scenario below for your consideration. This case does not represent any single individual reaching out to me for dialog, rather it represents a thread of similar concerns that are coming from calls and closed discussion groups on social media.
Gwyn Straker, PT, MS, past WPTA Ethics Committee Chair
Use of personal protective equipment and face masks
Background: The health care community is facing a shortage of PPE and face masks. As a result, various practice settings are developing rationing policies, procedures and practices on who receives PPE and facemasks and under what circumstances based on a decision-making tree. This is born out of necessity.
In response to the pandemic, Governors across the country are calling for “Safer at Home” “Pause” or “Shelter in Place” practices with exceptions for essential workers such as health care. Wisconsin included PT as an essential service. Some PT practice settings have created decision-making trees on when PT services are essential and how to deliver those services, taking into consideration social distancing.
Maeve is a physical therapist working in the home health setting. Maeve typically sees 6-7 patients a day with varying diagnoses. Maeve just received a referral to evaluate and treat a patient who is recovering from a total knee joint replacement. The patient has multiple co-morbidities. This patient also reports recent exposure to Covid-19 but to date is asymptomatic and therefore has not been tested. Your employer is unable to obtain PPE or N-95 protective face masks. Maeve is uncomfortable proceeding with this referral. Maeve approaches her supervisor with her concerns, but the supervisor believes that all patients must be served, and lack of protective gear is the current reality.
Maeve believes the patient merits treatment but is concerned that she may unknowingly expose other patients on her caseload to Covid-19 should this patient be an asymptomatic carrier because it will be impossible to maintain social distancing during treatment. Maeve realizes all PTs practicing in home health settings will be facing this challenge on a regular basis as patients recovering from Covid-19 related hospital stays are discharged.
Ethical Decision Making:
Realm: At first glance this looks as if it is at the individual realm because there is a referral requiring immediate attention. There may also be an institutional realm to this challenge. It is reasonable to assume that many home-based patients may at higher risk if exposed. It is also understood that a percentage of people are carriers but show no symptoms or could be pre-symptomatic. Other patients as well as staff could be asymptomatic or pre-symptomatic.
Individual Process: Maeve is already demonstrating moral sensitivity as demonstrated by identifying her concerns. Maeve believes that the solution may become clearer with more understanding of the issues (moral judgment).
At first glance, this scenario raises concerns about non-maleficence. Will harm come to the patient if they are not treated? Will harm come to other patients if this patient is treated? How does the PT factor in harm that might come to them personally? If this patient is treated and it is later determined that they did have Covid-19, what harm comes to others as a result of the PT being self-quarantined? What is the harm that might comes to the employer if patient is or is not treated? What harm comes to society if patient is or is not treated?
What do our core documents say?
Code of Ethics:
Principle 2A …act in the best interest of the patient over self interest
Principle 2C …provide necessary interest to allow patients to make informed decisions
Principle 2D…PT shall collaborate with patient on decisions about their health care
Additional documents that may inform your decision:
Things to Consider:
Course of Action:
1. What action can you take that would best serve this patient while also serving the greater good?
2. Are there any actions you can expect from your patient that might minimize your concerns?
3. What suggestions do you have for your employer regarding practices that impact this individual case?
Emergency Order 16 FAQ and Telehealth Guidance
Dear Health Care Provider,
The Department of Safety and Professional Services (Department) has received numerous inquiries regarding Emergency Order 16 and also the status of telemedicine/telehealth practice as a result of the COVID-19 public health emergency.
The emergency covers a wide range of issues across many health care professions. The order took action that will make it easier to quickly expand the health care workforce by readmitted those with expired licenses and by welcoming providers from other states. It will also enhance flexibility so providers can more effectively respond to areas of greatest need. Please read the order, linked above, and also reference this Frequently Asked Questions document for clarifications. Both address individuals who have expired licenses and wish to return to practice.
Also, the order addresses telemedicine specifically, but we have also received questions about telehealth practice for other providers. The practice of telehealth is generally allowed under existing Wisconsin law unless there is some profession-specific requirement or restriction. Credential holders must use their professional judgment to determine if telehealth is appropriate for the patient or client being treated, to abide by all other applicable rules of practice and professional conduct, and to be properly credentialed or authorized to practice in the state of Wisconsin. If someone can practice in Wisconsin via an Emergency Order, a compact, or a temporary or permanent license, that individual can practice telehealth in Wisconsin and provide services to Wisconsin residents to the same extent as similarly licensed Wisconsin practitioners.
The Wisconsin Medical Examining Board has the only telemedicine rule currently in effect in Wisconsin. This rule may be found at Wis. Admin. Code Med chapter 24. While this rule applies only to the Medical Examining Board, many of the concepts in this rule may be informative to credential holders in other professions. Here is a link to this rule. Note that portions of this rule were suspended when Governor Evers issued Emergency Order 16. Please review both Med chapter 24 as well as the statutory and rule provisions governing your profession when evaluating telemedicine/telehealth practice options during the COVID-10 public health emergency.
The Department is not able to answer legal questions regarding what the standard of care requires for any specific profession or any specific situation a credential holder may encounter. If practice-related questions arise, the Department encourages credential holders to consult with a supervisor, with their own private or institutional legal counsel, with their colleagues within the profession, or other sources familiar with their profession’s standards of practice. Profession-related statutes and rules can be found by clicking on a profession under the Rule/Statutes column here.
Also, there have been recent changes to Medicaid reimbursement of telehealth services. The Wisconsin Department of Health Services issued guidance on telehealth reimbursement changes and status during the COVID-19 public health emergency. The guidance is available here. The Office of the Commissioner of Insurance has also sent this letter regarding related insurance (malpractice) issues to insurers.
This information will be posted to our website. Please visit often, as we are updating it daily as decisions are made and new information is available.
Dawn B. Crim
Department of Safety and Professional Services
Please continue to visit the below mentioned Anthem Provider Communications page for frequent updates. As of 3/31/2020, new information was shared to include the codes and modifiers covered.
Wisconsin Provider Communications -
What codes would be appropriate to consider for telehealth (audio and video) for physical, occupational, and speech therapies?
For 90 days effective March 17, 2020, Anthem will waive member cost shares for telehealth visits for the following physical, occupational and speech therapies for visits coded with Place of Service (POS) “02” and modifier 95 or GT:
· Physical therapy (PT) evaluation codes 97161, 97162, 97163, and 97164
· Occupational (OT) therapy evaluation codes 97165, 97166, 97167, and 97168
· PT/OT treatment codes 97110, 97112, 97530, and 97535
· Speech therapy (ST) evaluation codes 92521, 92522, 92523, and 92524
· ST treatment codes 92507, 92526, 92606, and 92609
PT/OT codes that require equipment and/or direct physical hands-on interaction and therefore are not appropriate via telehealth include: 97010-97028, 97032-97039, 97113-97124, 97139-97150, 97533, and 97537-97546
Per Steve Tyska, MD, Chief Medical Officer, Wisconsin Department of Health, Division of Medicaid Services on 3/27/20 via call with Lynn Steffes, PT, DPT, the Medicaid Therapy Telehealth is being addressed along with several others. In the interim, do NOT withhold care from Medicaid recipients that can be properly managed via telehealth. Bill the Medicaid approved therapy codes for services. Use the telehealth modifier.
Thank you for serving our most vulnerable citizens.
Lynn Steffes, PT, DPT, WPTA Payment Specialist
For a list of current telehealth billing guidelines as of March 27, click here.
For telehealth payment updates as of April 1 click here
APTA COVID-19 E-visit Quick Reference - http://www.apta.org/COVID-19/E-Visit/QuickReference/
APTA Telehealth FAQs - http://www.apta.org/PTinMotion/News/2020/03/18/E-VisitFAQs/
Acute Care Resources - https://www.acutept.org/page/COVID19
APTA Private Practice Section offers Many Resources for all to Use - https://ppsapta.org/physical-therapy-covid-19.cfm#
Special Edition of Impact Magazine on COVID-19 - https://lsc-pagepro.mydigitalpublication.com/publication/?i=655319
Important Information for Early Intervention Providers: - https://www2.ed.gov/policy/speced/guid/idea/memosdcltrs/qa-covid-19-03-12-2020.pdf?utm_content=&utm_medium=email&utm_name=&utm_source=govdelivery&utm_term=
Guidance for Home Health Providers - https://aptahhs.memberclicks.net/coronavirus--information-for-providers
Telehealth Billing Information:
For a list of current telehealth billing guidelines as of March 27, click here.
New Medicare Telehealth Billing Opportunities for the COVID-19 Response
As of March 17, 2020, CMS has relaxed its telehealth requirements in response to COVID-19. Per these updates, Medicare will reimburse PTs, OTs, and SLPs for certain telehealth services—as noted by the code list below—that occurred on March 6 or later.
Updated Coverage of Rehab Therapy Telehealth
As per CMS’s latest update, PTs, OTs, and SLPs can bill Medicare (and receive payment) for the following telehealth services:
• 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.”
It’s important to note, though, that these codes apply exclusively to what CMS calls “E-Visits.” According to the fact sheet for this update, “These services can only be reported when the billing practice has an established relationship with the patient. For these E-Visits, the patient must generate the initial inquiry and communications can occur over a 7-day period.”
Per CMS, “E-Visits” differ from “Telehealth Visits,” which encompass any “office, hospital visits and other services that generally occur in-person.” PTs, OTs, and SLPs still are not included in the list of providers who are eligible to conduct Telehealth Visits under Medicare.
As the fact sheet states, “Distant site practitioners who can furnish and get payment for covered telehealth services (subject to state law) can include physicians, nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologists, clinical social workers, registered dietitians, and nutrition professionals.”
Here are some other key things to know about E-Visits per the waiver release:
• “These services can only be reported when the billing practice has an established relationship with the patient.
• This is not limited to only rural settings. There are no geographic or location restrictions for these visits.
• Patients communicate with their doctors without going to the doctor’s office by using online patient portals.
• Individual services need to be initiated by the patient; however, practitioners may educate beneficiaries on the availability of the service prior to patient initiation.
• The services may be billed using CPT codes 99421-99423 and HCPCS codes G2061-G2063, as applicable.
• The Medicare coinsurance and deductible would generally apply to these services.”
Additionally, when billing Medicare for E-Visits during the COVID-19 response period, rehab therapists should use the POS 11 or 12 (indicating they are located in an office or a home, respectively) as well as the CR modifier (indicating the services are catastrophe/disaster related)—not the 95 modifier.
HHS Office for Civil Rights (OCR) will waive HIPAA violation penalties against providers who offer “good faith” services to patients through everyday communication technologies (e.g., Skype or Facetime).
Non-Coverage of Rehab Therapy Telehealth and Patient Cash-Pay
As with all medically necessary services, third-party payer coverage is only part of the patient’s decision process. Consider dry needling: noncoverage in that case creates an opportunity to discuss the benefits of the service.
If a service is not covered by a payer for which you are a preferred provider, you may collect payment directly from patients at the time of service. However, before you do this, create a fee schedule for your telehealth services, and create a transparent billing process for your patients. Notify these patients (in writing) that telehealth services are not covered by their payer, and clearly establish the projected cost as well as when you expect payment. If you are not a preferred provider, you are not bound by their noncoverage of your services.
Modifier 95, when applied, designates that the services were delivered synchronously in real-time using a HIPAA-compliant program. The modifier is available for use with the new codes made available to rehab therapists as part of the COVID-19 response.
Modifier GT, when applied, designates that the services were delivered synchronously in real-time using a HIPAA-compliant program. GT is the modifier that is most commonly used for telehealth claims. Per the AMA, the modifier means “via interactive audio and video telecommunications systems.” You can append GT to any CPT code for services that were provided via telemedicine
Modifier GQ, when applied, designates that the services were delivered asynchronously using a HIPAA-compliant program. This is considered an “old” modifier and method of delivering telehealth, and it’s slowly getting replaced by synchronous technologies.
The CR modifier—which indicates that services are catastrophe/disaster-related—is mandatory when billing Medicare using the CPT codes for COVID-19-related E-Visits, which were recently made available to rehab therapists. (These codes are defined in the “Updated Coverage of Rehab Therapy Telehealth” subsection below.) This modifier is reserved for claims for which Medicare Part B payment is conditioned directly or indirectly on presence of a “formal waiver” like the one issued in response to COVID-19. It should be used for qualifying Part B items and services related to both institutional and non-institutional billing.
To purchase the webinar please visit https://wpta.org/events/webinars/?recID=E6198DF5-B89E-1B1C-945BD028C6FEA4C9
Technology in healthcare is rapidly expanding to all areas of patient care. Telehealth is the use of electronic communication to remotely provide health care information and services. This 1.5-hour introduction to telehealth will give attendees a basic understanding of telehealth including the different models of technology, options for use in practice, practice issues addressed by telehealth, regulatory and payment issues of telehealth, and platform options. This 1.5 hour course will enable the participant to understand and integrate current best evidence in telehealth into clinical practice.
Assembly Bill 581 was signed into law on March 3, 2020 by Governor Evers. This bill allows the Physical Therapy Examining Board (PTEB) to promulgate rules related to the supervision of student physical therapists (SPTs) and student physical therapist assistants (SPTAs). Prior statutory language was unclear and caused some clinical sites to decline taking SPTAs.
The PTEB can now begin the process of promulgating rules that clarify supervision requirements. We anticipate that the new rules will result in more clinical sites accepting SPTAs for clinical rotations. Thank you to Rep. VanderMeer for sponsoring the bill, and to Shari Berry, Western Technical College Program Chair and PTEB Chair, SPTAs Amber Orlikowski, Emily Kastner, Justin Nedvidek, and WPTA lobbyists Annie Early and Jeremey Shepherd for representing the WPTA, and helping to get this bill passed!