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We are grateful that The Centers for Medicare and Medicaid Services (CMS) granted several waivers and flexibilities for telehealth during the pandemic. Even though it was a struggle for therapy providers and advocacy groups to obtain approval for Physical Therapists, Occupational Therapists, and Speech Language Pathologists to be approved providers, we finally got there. However, in these times of a Public Health Emergency (PHE), how will our telehealth documentation hold up against future Medicare audits?

That’s right, Medicare audits!  In my September blog, I talked about the resumption of the Targeted Probe and Educate (TPE) audits. We are seeing TPEs for both Part A and Part B providers. For Medicare Part A, PDPM HIPPS code-focused audits and on the Medicare Part B side, Therapeutic Exercise (CPT code 97110), Therapeutic Activities (CPT code 97530), and Manual Therapy (CPT code 97140). I am sure there is more to come.

Telehealth focused audits will be coming, it’s just a matter of time. We must ensure that our documentation supports the clinical benefit of telehealth for the patient at a minimum. The Interim Final Rule April 6, 2020, CMS provides some examples of telehealth clinical benefits to include:

  • Ability to diagnose a medical condition in a patient population without access to clinically appropriate in-person diagnostic services.
  • Treatment option for a patient population without access to clinically appropriate in-person treatment options.
  • Reduced rate of complications.
  • Decreased rate of subsequent diagnostic or therapeutic interventions (for example, due to reduced rate of recurrence of the disease process).
  • Decreased number of future hospitalizations or physician visits.
  • More rapid beneficial resolution of the disease process treatment.
  • Decreased pain, bleeding, or other quantifiable symptom.
  • Reduced recovery time.

Documentation of the telehealth visit is important to support your telehealth claim, which is easily identified by the Medicare Administrative Contractor (MAC) because of the required -95 modifier denoting the service was telehealth. We should be documenting our normal therapeutic interventions and add the following information below as a best practice.

  1. State that the visit or treatment was provided via telehealth;
  2. State that consent was obtained from the patient to provide telehealth visit/treatment;
  3. State the location of the patient (home; SNF; AL Apartment; IL Apartment; etc.);
  4. State the location of the therapist; (keep in mind that the patient must be in the state where the therapist is licensed)
  5. State if any additional people participated in the telehealth therapy visit at either site.

These five bullet points above may seem to be too much information to add in the documentation. However, when fighting a denial, it’s important to have as much supporting documentation as possible to support your telehealth visit/treatment.

Gina Elkins

Senior director of Compliance and Regulatory Strategy