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Payment and Coverage Considerations for Telepractice Services During Coronavirus/COVID-19

Updated June 24, 2020

Audiologists and SLPs should be aware of the following payment and coverage issues as you consider implementing telepractice as an alternative service delivery model during the COVID-19 pandemic. ASHA also provides COVID-19 updates, including public policy updates, telepractice resources, clinical considerations, and other important resources to help you through this time.

NOTE: Policies regarding COVID-19 and telepractice continue to evolve. Although many payers are modifying telepractice policies, others are not. Broad statements regarding the availability or expansion of telepractice do not apply to all payers or directly to audiology and speech-language pathology services. Leaders in health care across public and private sectors are exploring options for expanding access, but significant policy changes take time. It is critical to check with your payer before initiating a new type of service or service delivery model, such as telepractice. Providers must understand the standing compliance requirements for payment for each of their payers. ASHA provides ongoing policy analysis and updates to members here and on ASHA’s COVID-19 Updates page.

On this page: 

Changes to Telepractice Coverage Due to COVID-19

More payers have expanded telepractice services to audiologists and SLPs.

More states and payers have loosened telepractice policies or expanded coverage to additional provider types during the COVID-19 pandemic, including audiologists and SLPs. ASHA continues to advocate for such changes and will post updates on this page as we become aware of payer-specific expansion of audiology and speech-language pathology telepractice services. Remember, telepractice guidelines vary among payers (Medicare, Medicaid, commercial insurers), so it's important to verify with specific payers before starting services. You should also be aware of changing state practice laws and regulations [PDF].

Clinicians are encouraged to monitor when current expansions related to the public health emergency (PHE) are set to end. (added 6/24/20)

Clinicians should carefully monitor when federal and state PHEs will end, as dates could vary and will impact the availability of telepractice services in health care and educational settings.

According to Medicare staff, the federal PHE is set to end on July 26, 2020. This means that federal waivers related to the PHE, including HIPAA flexibilities and Medicare coverage of audiology and speech-language pathology telepractice services, will also end at that time. However, the date may be extended based on evolving circumstances.

States may also set different dates for ending the PHE locally. This means that temporary state licensing, Medicaid, and local education agency expansions could end at different times than federal expansions. 

Commercial payers may also opt to maintain expansions beyond state or federal PHE dates.

Work directly with your facility to determine coverage and payment for telepractice services provided in hospital outpatient settings and inpatient settings.

Most payers are focused on expanding telepractice services in non-facility outpatient settings (e.g., private practices, clinics). However, many clinicians working in inpatient or facility-based settings may have questions about coverage and payment as they begin using telecommunication technology to deliver services to patients. Please work with your facility, billing personnel, administrators, and/or compliance officer to determine the payer’s billing and coverage policies for inpatient or facility-based services, as this may differ from outpatient non-facility billing and can change quickly during this time. ASHA continues to work with payers on comprehensive coverage of telepractice services across settings and will post information as we learn more about inpatient or facility-based billing.

Medicaid, TRICARE, and Commercial Plans

There is significant progress expanding telepractice services across state Medicaid programs and commercial insurance plans.

There is significant progress expanding telepractice coverage for audiologists and SLPs as states, Medicaid programs, commercial payers, and TRICARE turn their attention to broader health care needs. You can review ASHA’s state-by-state Medicaid and emergency order [PDF] and commercial insurance [PDF] tracking resources for a listing of payers and Medicaid programs that have expanded telepractice services during the COVID-19 pandemic.

ASHA updates these resources as new information becomes available. Please check them frequently.

Medicare

Medicare now covers telepractice services provided by audiologists and SLPs.

Medicare now allows audiologists and SLPs to provide telehealth services to Medicare Part B (outpatient) beneficiaries, retroactive to March 1, 2020, and for the duration of the public health emergency. CMS announced this expansion in an April 30, 2020, press release and its COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers [PDF]. See ASHA’s webpage on Medicare coverage of telehealth services during COVID-19 for details. 

Although the list of covered audiology and speech-language pathology services is not comprehensive, this is positive progress and ASHA will continue to advocate for additional coverage. ASHA also remains committed to advocating for full Medicare coverage of telepractice for audiologists and SLPs beyond the public health emergency.

Clinicians may be able to provide noncovered outpatient telepractice services to Medicare beneficiaries through a private pay arrangement.

Because audiologists and SLPs may now provide some services via telepractice to Medicare beneficiaries, they must be enrolled providers and submit claims for those covered services for reimbursement from Medicare. However, audiologists and SLPs may provide telepractice services to Medicare beneficiaries and enter into a private pay contract to receive reimbursement for services not currently covered via telepracticewith the patient's consent.

Medicare has released additional guidance for telepractice services in institutional settings. (added 6/24/20)

Medicare has slowly released additional guidance about telehealth services in institutional settings, such as skilled nursing facilities and hospital outpatient departments. However, guidelines still vary depending on the type of setting and whether services are paid under Medicare Part A or Part B. See ASHA's web page on Medicare coverage of telehealth services during COVID-19 for additional information on institutional billing.

Getting Started

Follow current state and payer policies related to telepractice in the absence of specific emergency guidelines.

Follow existing payer policies and state and federal regulations for telepractice when there isn't specific guidance on telepractice services during emergencies. 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:

Coding and Billing

Coding for telepractice services is similar to coding for in-person services, but check with each payer about the approved CPT code list and associated modifiers before you submit a claim.

You should report Current Procedural Terminology (CPT ® American Medical Association) codes and follow the same guidelines for appropriate billing of telepractice services as you would when providing in-person services. Payers typically also require a specific modifier or place of service code to distinguish telepractice services from in-person services. ASHA provides general guidance on coding for telepractice services but payer guidelines vary. 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 check-ins, or other similar services do not replace CPT codes for full evaluation and treatment services.

Many payers, including Medicare, have implemented CPT or Healthcare Common Procedure Coding System (HCPCS) codes for communication technology-based services such as e-visits (G2061-G2063 or 98970-98972), virtual check-ins (G2010, G2012), 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 payers may allow telepractice services provided over the phone (often called “telephonic” services) if a patient doesn’t have the ability to participate over an audiovisual platform. This is different from the telephone assessments listed here and should probably be reported using the specific CPT codes for evaluation or treatment.

HIPAA Flexibilities

Federal laws and regulations may affect your ability to provide telepractice services. 

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 and COVID-19 considerations for schools for additional information on HIPAA and FERPA.

Note: CMS temporarily waived enforcement of HIPAA requirements during the federally declared national emergency related to COVID-19. Under some circumstances, including in private pay situations, clinicians may have increased flexibility to use a non-public facing communications platform that allows direct, real-time communication between patient and provider.

Loosened HIPAA regulations don’t apply across the board.

The Department of Health and Human Services (HHS) Office for Civil Rights (OCR) recently relaxed HIPAA enforcement of federal penalties, providing more flexibilities for health care providers to choose telepractice platforms. Although this will help audiologists and SLPs in many circumstances where they can provide telepractice services, other payer policies may still apply and can impact reimbursement of your services. Providers must ensure due diligence to payer policy at all times, but especially when providing a new service or a new delivery model, such as telepractice. Here are key considerations based on payer type:

  • HIPAA flexibilities apply for self-pay patients who have no insurance or whose plans allow out-of-pocket payment arrangements.
  • Commercial insurance plans may implement policies at their discretion, so check with and follow each payer’s policy.
  • Although Medicaid is heavily guided by federal policy, each state Medicaid program will have some state-specific variation. Relaxation of HIPAA requirements may also apply to Medicaid, but check with your particular program directly.
  • Medicare and TRICARE follow federal policy and have relaxed HIPAA requirements.

When Telepractice Isn't an Option

You may be able to work directly with payers to waive certain requirements for continuity of care.

You may determine that telepractice or other service delivery models aren’t an option for you or some of your patients/clients/students. In those cases, contact your payer or educational agency directly if you're concerned about violating an established education plan/plan of care by failing to provide treatment due to COVID-19. State agencies and payers generally allow missed sessions or a “hold” on care due to unforeseen circumstances, such as illness or inclement weather. They may also waive requirements related to disruption of care during emergencies. If you decide to place an individual on hold due to COVID-19, determine how long the hold should be, note the rationale for the hold in your documentation, and establish a plan to assess when to resume services.

ASHA provides additional guidance for audiologists and SLPs regarding in-person services and documentation of delays/gaps in service.

What ASHA Is Doing to Help (and What You Can Do Too!)

ASHA continues to advocate for coverage of telepractice services across all major payers during the public health emergency.

Advocacy for comprehensive coverage and equitable reimbursement of audiology and speech-language pathology services—including telepractice—is a key health care priority of ASHA’s 2020 Public Policy Agenda. ASHA successfully advocated for temporary access to audiology and speech-language pathology telepractice services under Medicare. See ASHA’s advocacy webpage for a full list of ASHA’s official comments and letters to Congress, states, and Medicare during this time.

ASHA has also prioritized additional advocacy urging payers to support coverage of medically necessary audiology and speech-language pathology telepractice services on an emergency basis during this time. As a result, ASHA members have seen ongoing expansion of services across state Medicaid programs, commercial payers, and TRICARE.

ASHA is now prioritizing advocacy urging Congress and payers to support permanent coverage of telepractice services. (added 6/24/20)

As states and payers begin to consider telepractice beyond the public health emergency, 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 COVID-19 pandemic.

In the meantime, it's critical for clinicians to use, code, and bill telepractice according to payer specifications to increase the chances of retaining telepractice services beyond the public health emergency. Here are some key considerations to guide clinicians on doing that.

Local advocacy is important to our efforts to expand telepractice services.

ASHA encourages members to contact their local payers directly, particularly commercial insurers and state Medicaid programs. Use ASHA's new Evidence Map on telepractice to find support for your discussions regarding the value of telepractice services. You can also use ASHA’s template letter for members [DOC] or state associations [DOC] and recommendations for telepractice coverage [PDF] to urge plans to expand audiology and speech-language pathology services. 

For additional advocacy support in your state, contact your state speech-language-hearing association.

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

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