Payment and Coverage of Audiology and Speech-Language Pathology Telepractice Services

Telepractice is considered an appropriate service delivery model for audiologists and speech-language pathologists (SLPs), when clinically appropriate. However, clinicians must ensure that telepractice services are delivered within the confines of clinical and practice guidelines, state and federal laws and regulations, and payer policies. The following information focuses on policies related to payment for telepractice services.

On this page:

• Getting Started
• State Laws and Regulations
• Privacy and Security
• Payer Policies
• Coding and Billing
• Advocating for Telepractice Coverage
• Additional Resources
• Questions?

Getting Started

It’s important to research federal and state laws and regulations and payer policies before beginning telepractice services. Remember, policies vary by state and payer, and continue to change, so it's important to stay up-to-date. Always check with your employer, payer, and state licensing board for final guidance before engaging in telepractice. Here are key things you can do to prepare:

• Check whether your state covers telepractice by audiologists or SLPs. If a state does not authorize audiologists or SLPs to provide services via telepractice, this mode of service delivery will not be an option in that state, even if payers may cover telepractice services.
• Learn general principles of coding and payment for telepractice services.
• Contact your payers directly for additional guidance regarding services that are covered when provided via telepractice. Their policies may differ from state regulations.
• Follow best practice and legal requirements for telepractice, including using Health Insurance Portability and Accountability Act (HIPAA)-compliant software. Learn more through ASHA’s Practice Portal on telepractice, the Center for Connected Health Policy, and the American Telemedicine Association.
• Use ASHA's telepractice checklists to help keep track of key policies and regulations for each patient/client/student.
• Telepractice billing and coding compliance checklist for health care services [PDF]
• Telepractice checklist for school-based professionals [PDF]

State Laws and Regulations

Many states have licensure requirements and policies regarding telepractice that audiologists and SLPs should be aware of. Many have also passed laws and regulations requiring state Medicaid agencies or commercial insurance plans to cover services delivered via telepractice, if those same services are covered when in person. See ASHA's state-by-state pages for information on state-specific telepractice laws and regulations. Although these laws may allow audiologists and SLPs to provide telepractice services, clinicians should also consider payer policy before proceeding. Payers may not cover telepractice services, or may limit the type of services included in their telepractice benefit. Before you begin providing services via telepractice, always verify with each payer that they cover audiology or speech-language pathology telepractice services and confirm payer guidelines for coverage, payment, billing, coding, modifier use, and student/clinical fellow supervision.

Privacy and Security

Clinicians should be aware of federal laws and regulations related to privacy and security of patient and student records. For example, the Health Insurance Portability and Accountability Act (HIPAA) protects the transmission of health-related information and the Family Educational Rights and Privacy Act (FERPA) protects the privacy of student educational records. Although FERPA gives parents the right to consent to disclosure of personally identifiable information within educational records, school systems that receive Medicaid reimbursement for school-based services may also be bound by HIPAA requirements. See ASHA’s Practice Portal for additional information on telepractice privacy and security for additional information on HIPAA and FERPA.

Enforcement of HIPAA rules was loosened for Medicare and Tricare services during the PHE to help clinicians choose telepractice platforms that did not comply with HIPAA privacy and security requirements. State Medicaid programs and other payers could elect to follow the loosened rules. However, enforcement has resumed following the end of the federal PHE. Resources to help you stay in compliance include:

• ASHA’s Practice Portal on Telepractice (see Privacy and Security)
• ASHA’s Overview of HIPAA
• Center for Connected Health Policy
• American Telemedicine Association

Payer Policies

Audiologists and SLPs should keep in mind that although a state may have passed telepractice payment and coverage laws, this does not guarantee that payers will cover these services. In addition, certain insurance plans are exempt from state mandates. Always verify payer coverage policies before beginning to provide telepractice services.

Medicare

Note: Medicare will continue to temporarily cover telepractice services by audiologists and SLPs through December 31, 2024. Please review ASHA’s detailed information before beginning telepractice services with Medicare beneficiaries at this time.

Without Congressional action, audiologists and SLPs will not be statutorily authorized Medicare providers of telepractice after 2024 and clinical audiology and speech-language pathology services may not remain on the list of Medicare telepractice services payable under the Medicare Physician Fee Schedule. As a result, evaluation and treatment provided by audiologists and SLPs via telepractice will not be Medicare covered services beginning in 2025 and are exempt from Medicare requirements. Audiologists and SLPs may enter into a private pay contract with Medicare beneficiaries to furnish the telepractice services at the request of the patient. Learn more about the exemption before entering into a private pay agreement with a Medicare beneficiary for services provided via telepractice.

Certain value-based payment models (also called alternative payment models), including ACO Reach, allow broad telepractice coverage as one of its benefits enhancements. If you treat patients in value-based payment arrangements, refer to your patient’s specific model for additional details on telepractice waivers and flexibility.

Medicaid

CMS encourages state Medicaid agencies to develop approaches to telepractice and coverage expansion, but each state’s Medicaid agency can make their own guidelines for telepractice coverage and payment. Although some states have passed laws requiring the Medicaid agency to reimburse for services delivered via telepractice, audiologists and SLPs should contact the Medicaid agency for guidance on the following:

• Which services may or may not be covered when delivered via telepractice
• What provider types are eligible to deliver services via telepractice
• Which Current Procedural Terminology (CPT ®) codes are eligible for telepractice
• Which modifiers and/or place of service codes should be used to indicate that services were delivered via telepractice

Commercial (Private) Insurance

Each insurance plan can decide whether they will cover telepractice services. Like Medicaid, although some states may have passed laws requiring insurance plans to cover telepractice services, audiologists and speech-language pathologists should contact the plan for guidance on the following:

• Whether the plan is subject to state mandates (if applicable)
• Which services may or may not be covered when delivered via telepractice
• What provider types are eligible to deliver services via telepractice
• Which CPT codes are eligible for telepractice
• Which modifiers and/or place of service codes should be used to indicate services were delivered via telepractice

Coding and Billing

CPT Codes

Coding for evaluation and treatment services is typically accomplished using the same CPT codes, regardless of mode of service delivery. As such, audiologists and SLPs providing telepractice services should report CPT codes just as you would if the services were provided in person and follow the same guidelines for accurate billing. For example, a brief check-in via a telepractice platform should not be reported with an evaluation or treatment CPT code (such as 92507 or 92626). See ASHA's coding and payment web pages for a full list of audiology and speech-language pathology related CPT codes. Payers may also have a specific list of CPT codes approved for telepractice services. Always verify with the payer before initiating services.

E-Visits, Virtual Visits, Remote Monitoring, and Other Communication Technology-Based Services

Many payers, including Medicare, have implemented CPT or Healthcare Common Procedure Coding System (HCPCS) codes for communication technology-based (CTB) services such as e-visits ( 98970-98972), remote therapeutic monitoring (98975-98981), remote image/video assessments (G2250), virtual check-ins (G2251), or telephone assessments (98966-98968). However, these generally do not replace full evaluation or treatment services reported using other CPT codes (e.g., 92507 for speech and language treatment, 92603 for cochlear implant programming). Think of these as brief check-ins or consultations to mitigate the need for an office visit or a full evaluation or treatment service.

Some states and payers may allow telepractice services provided over the phone (often called "audio-only" or “telephonic” services) if a patient doesn’t have the ability to participate over an audiovisual platform. This is different from the telephone assessments listed above and should probably be reported using the specific CPT codes for evaluation or treatment.

See ASHA’s resource for more information on the correct use of CTB services.

Payment Rates for Telepractice Services

Most payers, including Medicare, currently pay providers at the same rate for both in-person and telepractice services, when covered. When establishing payment rates for telepractice services, ASHA recommends following that precedent, given that most telepractice services are billed using the same CPT codes for in-person services. Some adjustments to rates can be made to accommodate the financial needs of the patient under a written policy that applies to all patients, regardless of the type of insurance or service delivery model used.

As payers continue to assess their telepractice coverage, they may also consider setting lower rates for services provided via telepractice. Although many states have passed parity laws to ensure some coverage and payment for telepractice services, many of these laws require coverage of services provided via telepractice but do not explicitly discuss payment rates. As a result, clinicians may see different rates between in-person and telepractice visits. ASHA continues to advocate for true payment parity between telepractice and in-person services, and clinicians can too! Audiologists and SLPs can use ASHA’s telehealth data factsheet [PDF] to help start conversations with payers regarding payment parity and the value of telepractice services.

Modifiers

Modifiers related to telepractice—available through both the CPT and HCPCS coding systems—are appended to CPT codes to indicate mode of service delivery. To append a modifier, place it in the "modifier" section of the claim, on the same line as the CPT code. Audiologists and SLPs should check with each payer to verify correct use of modifiers to reflect telepractice services. Payers may also opt to use a place of service (POS) code to indicate services conducted via a telepractice system.

HCPCS

GQ Telehealth service rendered via asynchronous telecommunications system

GT  Telehealth service rendered via interactive audio and video telecommunications system

CPT

95  Synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system

Note: Modifier 95 was created through the CPT system and can be appended to CPT codes to reflect services that were provided via real-time telecommunication systems. This code does not replace the existing GQ and GT modifiers that were created through HCPCS by the Centers for Medicare & Medicaid Services (CMS). Clinicians should check with individual payers regarding use of telepractice-related modifiers on the claim form.

Place of Service (POS) Codes

POS codes are used on claims to indicate the specific type of location where services were provided. Clinicians should verify with individual payers regarding implementation and use of the POS codes for telepractice, listed below. More information on POS codes is available on the CMS website.

02  Telehealth Provided Other than in Patient’s Home (The location where health services and health related services are provided or received, through telecommunication technology. Patient is not located in their home when receiving health services or health related services through telecommunication technology.)

10  Telehealth Provided in Patient's Home (The location where health services and health related services are provided or received through telecommunication technology. Patient is located in their home [which is a location other than a hospital or other facility where the patient receives care in a private residence] when receiving health services or health related services through telecommunication technology.)

If a payer does not recognize POS 02 or POS 10 for telepractice, clinicians should report the POS that best reflects the location of the rendering provider, not the location of the patient. For example, if you provide services from your private practice or home office, consider using POS 11 for "office". POS 11 describes a setting other than a hospital or other facility where a health care professional routinely provides evaluation and treatment services.

See also: Medicare Telehealth Coding and Billing Guidelines

Advocating for Telepractice Coverage

Advocacy for comprehensive coverage and equitable payment of audiology and speech-language pathology services—including telepractice—is a key health care priority of ASHA’s Public Policy Agenda. During the COVID-19 PHE, ASHA prioritized additional advocacy urging payers to support coverage of medically necessary audiology and speech-language pathology telepractice services on an emergency basis during that time. As a result, ASHA members saw expansion of services across state Medicaid programs, commercial payers, and TRICARE. ASHA also successfully advocated for temporary access to certain audiology and speech-language pathology telepractice services under Medicare.

As states and payers continue to consider telepractice coverage after the PHE, ASHA is urging Congress, state Medicaid programs, and commercial insurers to permanently expand coverage of telepractice services to audiologists and SLPs. Clinicians can go to ASHA's Take Action site to ask your representatives to improve access to Medicare telepractice services beyond the 2-year extension through December 31, 2024.

Clinicians can also help with advocacy efforts at a local level by contacting commercial insurers and state Medicaid programs. Use ASHA's telehealth data factsheet [PDF] to help start conversations with payers regarding payment parity and the value of telepractice services. ASHA's Evidence Map on telepractice can also help you find support for your discussions.

Resources

• Department of Health and Human Services: Telehealth Policy
• ASHA’s Practice Portal on Telepractice
• ASHA’s State-by-State Telepractice Laws (select your state for more information)
• ASHA's Evidence Map on Telepractice

Questions?

Contact reimbursement@asha.org for additional information related to coding and payment for telepractice services. For clinical questions, audiologists can contact audiology@asha.org, SLPs in health care can contact healthservices@asha.org, and SLPs in schools can contact schools@asha.org. For questions about state laws and regulations, contact states@asha.org.