There is a lot going on as we face daily challenges with COVID-19 and the public health emergency.  I would like to take this opportunity to thank all of our front-line workers who work so hard every day.  THANK YOU for making a difference in the lives you touch!

Therapy providers everywhere were taken back by the addition of therapy codes in the Interim Final Rule, but in the same document, CMS stated that, Physical Therapists, Occupational Therapists, and Speech Language Pathologists are not approved ‘distant providers’, meaning that we cannot provide telehealth services. What?! Yes, we got the codes, but we were not approved telehealth providers.

Well, thank goodness that just a short four weeks following that initial Interim Final Rule, a second wave of flexibilities surfaced, and hallelujah,  Physical Therapists, Occupational Therapists, and Speech Language Pathologists were added as ‘distant providers’ in the second Interim Final Rule! Telehealth, here we come!!

What is telehealth? Telehealth is a two way, “real-time,” live interaction between a therapist and patient. This two-way, electronic audio and visual communication is an instrument used to deliver therapy assessment and treatment to patients, while the patient and the therapist are not in the same location.

But wait….telehealth cannot be billed on a UB-04 and after receiving CMS clarification on May 5, 2020, only those providers who bill on a 1500 professional claim can bill for telehealth.  What about outpatient therapy? If you bill on a 1500 form, therapists can provide, bill, and get reimbursed for telehealth therapy services.  But does that leave SNFs out of luck?

SNFs are not out of luck.  CMS states that, if the therapist and the patient are in the same location providing services through technology, this is considered “in-person” services and should not be billed as telehealth. We are calling these type of visits ‘virtual therapy sessions’. These virtual sessions are conducted utilizing the same two-way, real-time, live, audiovisual interaction between the resident and the therapist like in telehealth. The difference is that with virtual therapy sessions, the therapist and the resident are in the same location; under telehealth, the patient and therapist are in two separate locations. Virtual therapy sessions will improve resident engagement, allow for quicker screening, assessment, and treatment to avoid functional declines, improve quality of life, and decrease adverse effects from social isolation. Virtual therapy sessions can eliminate gaps in care and decrease exposure to illnesses.

Perhaps soon, CMS will provide guidance for SNFs regarding their ability to provide, bill, and get reimbursed for telehealth services.  But in the meantime, we can certainly provide virtual therapy sessions.


Gina Elkins

Director of Compliance and Regulatory Strategy