July 2020 Telehealth Updates
Dear Dr. Miner,
Attached to this email is a letter from the American Occupational Therapy Association regarding Utah’s telehealth policies for Medicaid. AOTA appreciates the flexibilities Utah has granted during the COVID-19 public health emergency and urges you to permanently implement policies that allow for reimbursement of telehealth services furnished by occupational therapy practitioners to allow your beneficiaries to receive these services within their home via telehealth.
I have also attached supporting documentation relative to occupational therapy and telehealth for your review.
Please let me know if you have any questions regarding the letter or enclosures. We look forward to hearing from you.
Manager, Reimbursement and Regulatory Policy
American Occupational Therapy Association
May 2020 Telehealth Updates
Thanks to sustained AOTA advocacy efforts, Medicare will now expand the 1135 waiver to reimburse occupational therapists for services provided to Medicare beneficiaries during the COVID-19 crisis.
Happy OT Month! UOTA is working hard on your behalf. Here are some updates and important information affecting occupational therapists in Utah.
Urge Congress to Reimburse OT Services via Telehealth
All you need to do is input your zip code and sign your name to send it to your representatives in Congress. It will only take less than 3 minutes. Access to telehealth services through Medicare would enable OTs and other providers to reduce the risk of spreading infection to their patients, who are often highly vulnerable to this virus.
- 3/31/2020: AOTA’s initial interpretation of CMS’s Interim Final Rule (IFR) to open up regulatory barriers across health care settings to respond to the COVID-19 crisis is that OT, PT and SLPs cannot bill for telehealth services, even though a group of therapy CPT codes we use were added to the list of telehealth services, including OT evaluation codes. AOTA is advocating strenuously with APTA and ASHA to have therapy practitioners added to the telehealth eligible provider list, with the belief that that the CARES Act gives CMS the authority to add practitioners. A full analysis is in development based on the CMS Press release and IFR.
- March 26, 2020: UnitedHealthcare will reimburse physical, occupational and speech therapy telehealth services provided by qualified health care professionals when rendered using interactive audio/video technology. State laws and regulations apply. Benefits will be processed in accordance with the member’s plan.This change is effective immediately for dates of service March 18 through June 18, 2020. Reimbursable codes are limited to the specific set of physical, occupational and speech therapy codes listed. UnitedHealthcare will reimburse eligible codes when submitted with a place of service code 02 and modifier 95.
Initial OT Compact Legislation Drafted
On February 25 and 26, 2020, the Council of State Governments (CSG) convened the Occupational Therapy Drafting Team in Washington, DC. The Drafting Team is expected to complete a draft compact this spring, which will be reviewed by the Occupational Therapy Advisory Group for comment. From there the draft will be distributed to stakeholders for comment in the summer of 2020.
The goal is to work with stakeholders to come to a consensus and finalize the occupational therapy compact legislation by early fall 2020. The process will then include efforts to work with state occupational therapy associations and state regulatory boards/agencies to introduce the licensure compact legislation in multiple states during the 2021 state legislative sessions.
- AOTA, APTA and ASHA are advocating with CMS to allow therapy to be provided via telehealth (the E-visits are not considered telehealth by CMS, for more details on Evisits, see: http://www.aota.org/Practice/Manage/telehealth/Nonphysician-Evisits.aspx)
- The CAREs act could be helpful on this front, see the first blurb related to telehealth in this update: http://www.aota.org/Advocacy-Policy/Congressional-Affairs/Legislative-Issues-Update/2020/Congress-Passes-Coronavirus-Aid-Relief-Economic-Security-Act.aspx
- AOTA, APTA and ASHA sent a letter to CMS on Friday and issued this statement: Joint Statement on Medicare Telehealth Expansion under 1135 Waiver Authority: http://www.aota.org/Advocacy-Policy/Federal-Reg-Affairs/News/2020/Joint-Statement-Medicare-Telehealth-Expansion.aspx
Resources from AOTA:
- Stateside has created a chart with state legislative actions, executive agency actions, gubernatorial actions, and local government actions related to the outbreak of the coronavirus: https://www.stateside.com/blog/2020-state-government-responses-covid-19
- The Center for Connected Health Policy (CCHPCA) has created a chart of state actions taken to remove policy barriers to telehealth utilization: https://www.cchpca.org/resources/covid-19-related-state-actions
- The National Conference of State Legislatures (NCSL) has compiled state legislation responding to COVID-19: https://www.ncsl.org/research/health/state-action-on-coronavirus-covid-19.aspx
- The Council of State Governments (CSG) has also compiled state-by-state resources such as executive orders, legislative sessions by state, state COVID-19 websites and resources, other mandates, etc: https://web.csg.org/covid19/